Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Controls should be in place to ensure that limitations on cash management in federal regulations are adhered to, including ensuring that drawdowns of federal funding are supported by proper documentation and are approved by an appropriate level of management and that Joint Programs maintain a written policy over the payment requests and drawdown of funds.
Condition/Context:
No support was provided for 2 of 2 samples.
[X ] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, controls over cash management were not operating effectively, particularly in ensuring that proper supporting documentation is maintained for drawdowns.
Effect:
Without an effective internal control system, an entity’s objectives in operations, reporting, and compliance cannot be achieved. Additionally, drawdowns and payment requests may have been made without proper supporting documentation.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-002.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Controls should be in place to ensure that limitations on cash management in federal regulations are adhered to, including ensuring that drawdowns of federal funding are supported by proper documentation and are approved by an appropriate level of management and that Joint Programs maintain a written policy over the payment requests and drawdown of funds.
Condition/Context:
No support was provided for 2 of 2 samples.
[X ] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, controls over cash management were not operating effectively, particularly in ensuring that proper supporting documentation is maintained for drawdowns.
Effect:
Without an effective internal control system, an entity’s objectives in operations, reporting, and compliance cannot be achieved. Additionally, drawdowns and payment requests may have been made without proper supporting documentation.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-002.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Controls should be in place to ensure that limitations on cash management in federal regulations are adhered to, including ensuring that drawdowns of federal funding are supported by proper documentation and are approved by an appropriate level of management and that Joint Programs maintain a written policy over the payment requests and drawdown of funds.
Condition/Context:
No support was provided for 2 of 2 samples.
[X ] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, controls over cash management were not operating effectively, particularly in ensuring that proper supporting documentation is maintained for drawdowns.
Effect:
Without an effective internal control system, an entity’s objectives in operations, reporting, and compliance cannot be achieved. Additionally, drawdowns and payment requests may have been made without proper supporting documentation.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-002.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Controls should be in place to ensure that limitations on cash management in federal regulations are adhered to, including ensuring that drawdowns of federal funding are supported by proper documentation and are approved by an appropriate level of management and that Joint Programs maintain a written policy over the payment requests and drawdown of funds.
Condition/Context:
No support was provided for 2 of 2 samples.
[X ] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, controls over cash management were not operating effectively, particularly in ensuring that proper supporting documentation is maintained for drawdowns.
Effect:
Without an effective internal control system, an entity’s objectives in operations, reporting, and compliance cannot be achieved. Additionally, drawdowns and payment requests may have been made without proper supporting documentation.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-002.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Controls should be in place to ensure that limitations on cash management in federal regulations are adhered to, including ensuring that drawdowns of federal funding are supported by proper documentation and are approved by an appropriate level of management and that Joint Programs maintain a written policy over the payment requests and drawdown of funds.
Condition/Context:
No support was provided for 2 of 2 samples.
[X ] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, controls over cash management were not operating effectively, particularly in ensuring that proper supporting documentation is maintained for drawdowns.
Effect:
Without an effective internal control system, an entity’s objectives in operations, reporting, and compliance cannot be achieved. Additionally, drawdowns and payment requests may have been made without proper supporting documentation.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-002.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must:
1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements.
2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319.
3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)).
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215.
When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR Section 180.300).
Condition/Context:
20.205 – Highway Planning and Construction Cluster
• 1 of 8 Individually Important Items (IIIs) had bidding/solicitation documentation but did not have proper approval.
• 2 of 8 IIIs had documentation of one quote obtained but no further documentation.
• 5 of 8 IIIs and 2 of 2 procurement samples had no bidding/solicitation support provided.
• 8 of 8 IIIs and 2 of 2 suspension and debarment samples did not have documentation of a suspension and debarment search prior to payment.
20.509 – Road Maintenance Programs
• 3 of 3 IIIs and 7 of 7 procurement samples had no bidding/solicitation support provided.
• 3 of 3 IIIs and 2 of 2 suspension and debarment samples did not have proper documentation provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, Joint Programs could be subject to questioned costs or other sanctions from funding agencies if they determine that Joint Programs did not assure full and open competition for the procurements and/or if vendors retained and paid from federal funds and are later found to be suspended or debarred.
Questioned Costs:
Known – $971,925 AL# 20.205
Known – $563,676 AL# 20.509
Repeat Finding:
Yes – 2021-005.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend that Joint Programs conduct training for staff to review procurement and suspension and debarment policies and procedures and maintain all records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must:
1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements.
2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319.
3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)).
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215.
When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR Section 180.300).
Condition/Context:
20.205 – Highway Planning and Construction Cluster
• 1 of 8 Individually Important Items (IIIs) had bidding/solicitation documentation but did not have proper approval.
• 2 of 8 IIIs had documentation of one quote obtained but no further documentation.
• 5 of 8 IIIs and 2 of 2 procurement samples had no bidding/solicitation support provided.
• 8 of 8 IIIs and 2 of 2 suspension and debarment samples did not have documentation of a suspension and debarment search prior to payment.
20.509 – Road Maintenance Programs
• 3 of 3 IIIs and 7 of 7 procurement samples had no bidding/solicitation support provided.
• 3 of 3 IIIs and 2 of 2 suspension and debarment samples did not have proper documentation provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, Joint Programs could be subject to questioned costs or other sanctions from funding agencies if they determine that Joint Programs did not assure full and open competition for the procurements and/or if vendors retained and paid from federal funds and are later found to be suspended or debarred.
Questioned Costs:
Known – $971,925 AL# 20.205
Known – $563,676 AL# 20.509
Repeat Finding:
Yes – 2021-005.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend that Joint Programs conduct training for staff to review procurement and suspension and debarment policies and procedures and maintain all records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must:
1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements.
2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319.
3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)).
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215.
When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR Section 180.300).
Condition/Context:
20.205 – Highway Planning and Construction Cluster
• 1 of 8 Individually Important Items (IIIs) had bidding/solicitation documentation but did not have proper approval.
• 2 of 8 IIIs had documentation of one quote obtained but no further documentation.
• 5 of 8 IIIs and 2 of 2 procurement samples had no bidding/solicitation support provided.
• 8 of 8 IIIs and 2 of 2 suspension and debarment samples did not have documentation of a suspension and debarment search prior to payment.
20.509 – Road Maintenance Programs
• 3 of 3 IIIs and 7 of 7 procurement samples had no bidding/solicitation support provided.
• 3 of 3 IIIs and 2 of 2 suspension and debarment samples did not have proper documentation provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, Joint Programs could be subject to questioned costs or other sanctions from funding agencies if they determine that Joint Programs did not assure full and open competition for the procurements and/or if vendors retained and paid from federal funds and are later found to be suspended or debarred.
Questioned Costs:
Known – $971,925 AL# 20.205
Known – $563,676 AL# 20.509
Repeat Finding:
Yes – 2021-005.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend that Joint Programs conduct training for staff to review procurement and suspension and debarment policies and procedures and maintain all records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must:
1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements.
2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319.
3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)).
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215.
When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR Section 180.300).
Condition/Context:
20.205 – Highway Planning and Construction Cluster
• 1 of 8 Individually Important Items (IIIs) had bidding/solicitation documentation but did not have proper approval.
• 2 of 8 IIIs had documentation of one quote obtained but no further documentation.
• 5 of 8 IIIs and 2 of 2 procurement samples had no bidding/solicitation support provided.
• 8 of 8 IIIs and 2 of 2 suspension and debarment samples did not have documentation of a suspension and debarment search prior to payment.
20.509 – Road Maintenance Programs
• 3 of 3 IIIs and 7 of 7 procurement samples had no bidding/solicitation support provided.
• 3 of 3 IIIs and 2 of 2 suspension and debarment samples did not have proper documentation provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, Joint Programs could be subject to questioned costs or other sanctions from funding agencies if they determine that Joint Programs did not assure full and open competition for the procurements and/or if vendors retained and paid from federal funds and are later found to be suspended or debarred.
Questioned Costs:
Known – $971,925 AL# 20.205
Known – $563,676 AL# 20.509
Repeat Finding:
Yes – 2021-005.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend that Joint Programs conduct training for staff to review procurement and suspension and debarment policies and procedures and maintain all records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must:
1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements.
2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319.
3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)).
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215.
When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR Section 180.300).
Condition/Context:
20.205 – Highway Planning and Construction Cluster
• 1 of 8 Individually Important Items (IIIs) had bidding/solicitation documentation but did not have proper approval.
• 2 of 8 IIIs had documentation of one quote obtained but no further documentation.
• 5 of 8 IIIs and 2 of 2 procurement samples had no bidding/solicitation support provided.
• 8 of 8 IIIs and 2 of 2 suspension and debarment samples did not have documentation of a suspension and debarment search prior to payment.
20.509 – Road Maintenance Programs
• 3 of 3 IIIs and 7 of 7 procurement samples had no bidding/solicitation support provided.
• 3 of 3 IIIs and 2 of 2 suspension and debarment samples did not have proper documentation provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, Joint Programs could be subject to questioned costs or other sanctions from funding agencies if they determine that Joint Programs did not assure full and open competition for the procurements and/or if vendors retained and paid from federal funds and are later found to be suspended or debarred.
Questioned Costs:
Known – $971,925 AL# 20.205
Known – $563,676 AL# 20.509
Repeat Finding:
Yes – 2021-005.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend that Joint Programs conduct training for staff to review procurement and suspension and debarment policies and procedures and maintain all records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must:
1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements.
2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319.
3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)).
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215.
When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR Section 180.300).
Condition/Context:
20.205 – Highway Planning and Construction Cluster
• 1 of 8 Individually Important Items (IIIs) had bidding/solicitation documentation but did not have proper approval.
• 2 of 8 IIIs had documentation of one quote obtained but no further documentation.
• 5 of 8 IIIs and 2 of 2 procurement samples had no bidding/solicitation support provided.
• 8 of 8 IIIs and 2 of 2 suspension and debarment samples did not have documentation of a suspension and debarment search prior to payment.
20.509 – Road Maintenance Programs
• 3 of 3 IIIs and 7 of 7 procurement samples had no bidding/solicitation support provided.
• 3 of 3 IIIs and 2 of 2 suspension and debarment samples did not have proper documentation provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, Joint Programs could be subject to questioned costs or other sanctions from funding agencies if they determine that Joint Programs did not assure full and open competition for the procurements and/or if vendors retained and paid from federal funds and are later found to be suspended or debarred.
Questioned Costs:
Known – $971,925 AL# 20.205
Known – $563,676 AL# 20.509
Repeat Finding:
Yes – 2021-005.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend that Joint Programs conduct training for staff to review procurement and suspension and debarment policies and procedures and maintain all records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must:
1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements.
2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319.
3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)).
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215.
When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR Section 180.300).
Condition/Context:
20.205 – Highway Planning and Construction Cluster
• 1 of 8 Individually Important Items (IIIs) had bidding/solicitation documentation but did not have proper approval.
• 2 of 8 IIIs had documentation of one quote obtained but no further documentation.
• 5 of 8 IIIs and 2 of 2 procurement samples had no bidding/solicitation support provided.
• 8 of 8 IIIs and 2 of 2 suspension and debarment samples did not have documentation of a suspension and debarment search prior to payment.
20.509 – Road Maintenance Programs
• 3 of 3 IIIs and 7 of 7 procurement samples had no bidding/solicitation support provided.
• 3 of 3 IIIs and 2 of 2 suspension and debarment samples did not have proper documentation provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, Joint Programs could be subject to questioned costs or other sanctions from funding agencies if they determine that Joint Programs did not assure full and open competition for the procurements and/or if vendors retained and paid from federal funds and are later found to be suspended or debarred.
Questioned Costs:
Known – $971,925 AL# 20.205
Known – $563,676 AL# 20.509
Repeat Finding:
Yes – 2021-005.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend that Joint Programs conduct training for staff to review procurement and suspension and debarment policies and procedures and maintain all records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must:
1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements.
2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319.
3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)).
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215.
When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR Section 180.300).
Condition/Context:
20.205 – Highway Planning and Construction Cluster
• 1 of 8 Individually Important Items (IIIs) had bidding/solicitation documentation but did not have proper approval.
• 2 of 8 IIIs had documentation of one quote obtained but no further documentation.
• 5 of 8 IIIs and 2 of 2 procurement samples had no bidding/solicitation support provided.
• 8 of 8 IIIs and 2 of 2 suspension and debarment samples did not have documentation of a suspension and debarment search prior to payment.
20.509 – Road Maintenance Programs
• 3 of 3 IIIs and 7 of 7 procurement samples had no bidding/solicitation support provided.
• 3 of 3 IIIs and 2 of 2 suspension and debarment samples did not have proper documentation provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, Joint Programs could be subject to questioned costs or other sanctions from funding agencies if they determine that Joint Programs did not assure full and open competition for the procurements and/or if vendors retained and paid from federal funds and are later found to be suspended or debarred.
Questioned Costs:
Known – $971,925 AL# 20.205
Known – $563,676 AL# 20.509
Repeat Finding:
Yes – 2021-005.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend that Joint Programs conduct training for staff to review procurement and suspension and debarment policies and procedures and maintain all records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Reporting requirements are contained in the following:
Financial reporting, 2 CFR section 200.328.
Monitoring and reporting program performance, 2 CFR section 200.329.
Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation.
Condition/Context:
15.029 – Judicial Services
Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports.
20.205 – Highway Planning and Construction Cluster
Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-006.
Recommendation:
Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Reporting requirements are contained in the following:
Financial reporting, 2 CFR section 200.328.
Monitoring and reporting program performance, 2 CFR section 200.329.
Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation.
Condition/Context:
15.029 – Judicial Services
Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports.
20.205 – Highway Planning and Construction Cluster
Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-006.
Recommendation:
Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Reporting requirements are contained in the following:
Financial reporting, 2 CFR section 200.328.
Monitoring and reporting program performance, 2 CFR section 200.329.
Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation.
Condition/Context:
15.029 – Judicial Services
Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports.
20.205 – Highway Planning and Construction Cluster
Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-006.
Recommendation:
Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Reporting requirements are contained in the following:
Financial reporting, 2 CFR section 200.328.
Monitoring and reporting program performance, 2 CFR section 200.329.
Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation.
Condition/Context:
15.029 – Judicial Services
Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports.
20.205 – Highway Planning and Construction Cluster
Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-006.
Recommendation:
Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Reporting requirements are contained in the following:
Financial reporting, 2 CFR section 200.328.
Monitoring and reporting program performance, 2 CFR section 200.329.
Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation.
Condition/Context:
15.029 – Judicial Services
Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports.
20.205 – Highway Planning and Construction Cluster
Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-006.
Recommendation:
Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Reporting requirements are contained in the following:
Financial reporting, 2 CFR section 200.328.
Monitoring and reporting program performance, 2 CFR section 200.329.
Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation.
Condition/Context:
15.029 – Judicial Services
Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports.
20.205 – Highway Planning and Construction Cluster
Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-006.
Recommendation:
Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Reporting requirements are contained in the following:
Financial reporting, 2 CFR section 200.328.
Monitoring and reporting program performance, 2 CFR section 200.329.
Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation.
Condition/Context:
15.029 – Judicial Services
Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports.
20.205 – Highway Planning and Construction Cluster
Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-006.
Recommendation:
Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
15.029 – Judicial Services
Investment of Advance Funds
Funds advanced, pending expenditure under this contract, shall be placed in appropriate savings, checking, or investment accounts. Such funds, when invested or deposited, shall be subject to the following:
(a) Invested only in obligations of the United States, or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission and which only invest in obligations of the United States or securities that are guaranteed by the United States; or,
Deposited only into accounts that are insured by an agency or instrumentality of the United States or are fully collateralized to ensure protection of the funds, even in the event of a bank failure.
20.205 – Highway Planning and Construction Cluster
Wage Rate Requirements
Compliance Requirements: The Wage Rate Requirements are applicable to construction work on federal-aid highways or on projects using ADHS or FLTTP funds. These requirements apply to federal-aid projects located within the right-of-way of a federal-aid highway. These requirements also apply to federal-aid projects funded by the STBG program that are located outside the right-of-way of a federal-aid highway, including projects funded under the Transportation Alternatives Set-Aside (except for projects funded under the Recreational Trails Program). FHWA has provided guidance on the applicability of these requirements at http://www.fhwa.dot.gov/construction/contracts/080625.cfm (23 USC 113 and 40 U.SC 14701).
Project Approvals
Compliance Requirements: FHWA project approval/authorization to proceed is required before costs are incurred for all phases or projects, except for certain property acquisition costs permitted under 23 USC 108, certain emergency repair work under 23 USC 125, and preliminary engineering under Section 1440 of the FAST Act (23 USC 121 note). Based on the Stewardship and Oversight agreement between the State DOT and the FHWA Division office, projects may be authorized under the authority in 23 USC 106(c), which allows the State DOT to assume responsibilities for designs, plans, specifications, estimates, contract awards, and inspection of progress. When FHWA authorizes a construction project or phase in a project agreement, the State DOT may incur costs; i.e., advertise for bids or use force account work (23 CFR sections 630.205(c), 635.112(a), 635.204, and 635.309).
Condition/Context:
• Management has not implemented an effective internal control system.
• No support was provided to test any special tests or provisions for these programs.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-007.
Recommendation: We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend Joint Programs maintain records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
15.029 – Judicial Services
Investment of Advance Funds
Funds advanced, pending expenditure under this contract, shall be placed in appropriate savings, checking, or investment accounts. Such funds, when invested or deposited, shall be subject to the following:
(a) Invested only in obligations of the United States, or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission and which only invest in obligations of the United States or securities that are guaranteed by the United States; or,
Deposited only into accounts that are insured by an agency or instrumentality of the United States or are fully collateralized to ensure protection of the funds, even in the event of a bank failure.
20.205 – Highway Planning and Construction Cluster
Wage Rate Requirements
Compliance Requirements: The Wage Rate Requirements are applicable to construction work on federal-aid highways or on projects using ADHS or FLTTP funds. These requirements apply to federal-aid projects located within the right-of-way of a federal-aid highway. These requirements also apply to federal-aid projects funded by the STBG program that are located outside the right-of-way of a federal-aid highway, including projects funded under the Transportation Alternatives Set-Aside (except for projects funded under the Recreational Trails Program). FHWA has provided guidance on the applicability of these requirements at http://www.fhwa.dot.gov/construction/contracts/080625.cfm (23 USC 113 and 40 U.SC 14701).
Project Approvals
Compliance Requirements: FHWA project approval/authorization to proceed is required before costs are incurred for all phases or projects, except for certain property acquisition costs permitted under 23 USC 108, certain emergency repair work under 23 USC 125, and preliminary engineering under Section 1440 of the FAST Act (23 USC 121 note). Based on the Stewardship and Oversight agreement between the State DOT and the FHWA Division office, projects may be authorized under the authority in 23 USC 106(c), which allows the State DOT to assume responsibilities for designs, plans, specifications, estimates, contract awards, and inspection of progress. When FHWA authorizes a construction project or phase in a project agreement, the State DOT may incur costs; i.e., advertise for bids or use force account work (23 CFR sections 630.205(c), 635.112(a), 635.204, and 635.309).
Condition/Context:
• Management has not implemented an effective internal control system.
• No support was provided to test any special tests or provisions for these programs.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-007.
Recommendation: We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend Joint Programs maintain records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
15.029 – Judicial Services
Investment of Advance Funds
Funds advanced, pending expenditure under this contract, shall be placed in appropriate savings, checking, or investment accounts. Such funds, when invested or deposited, shall be subject to the following:
(a) Invested only in obligations of the United States, or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission and which only invest in obligations of the United States or securities that are guaranteed by the United States; or,
Deposited only into accounts that are insured by an agency or instrumentality of the United States or are fully collateralized to ensure protection of the funds, even in the event of a bank failure.
20.205 – Highway Planning and Construction Cluster
Wage Rate Requirements
Compliance Requirements: The Wage Rate Requirements are applicable to construction work on federal-aid highways or on projects using ADHS or FLTTP funds. These requirements apply to federal-aid projects located within the right-of-way of a federal-aid highway. These requirements also apply to federal-aid projects funded by the STBG program that are located outside the right-of-way of a federal-aid highway, including projects funded under the Transportation Alternatives Set-Aside (except for projects funded under the Recreational Trails Program). FHWA has provided guidance on the applicability of these requirements at http://www.fhwa.dot.gov/construction/contracts/080625.cfm (23 USC 113 and 40 U.SC 14701).
Project Approvals
Compliance Requirements: FHWA project approval/authorization to proceed is required before costs are incurred for all phases or projects, except for certain property acquisition costs permitted under 23 USC 108, certain emergency repair work under 23 USC 125, and preliminary engineering under Section 1440 of the FAST Act (23 USC 121 note). Based on the Stewardship and Oversight agreement between the State DOT and the FHWA Division office, projects may be authorized under the authority in 23 USC 106(c), which allows the State DOT to assume responsibilities for designs, plans, specifications, estimates, contract awards, and inspection of progress. When FHWA authorizes a construction project or phase in a project agreement, the State DOT may incur costs; i.e., advertise for bids or use force account work (23 CFR sections 630.205(c), 635.112(a), 635.204, and 635.309).
Condition/Context:
• Management has not implemented an effective internal control system.
• No support was provided to test any special tests or provisions for these programs.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-007.
Recommendation: We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend Joint Programs maintain records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
15.029 – Judicial Services
Investment of Advance Funds
Funds advanced, pending expenditure under this contract, shall be placed in appropriate savings, checking, or investment accounts. Such funds, when invested or deposited, shall be subject to the following:
(a) Invested only in obligations of the United States, or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission and which only invest in obligations of the United States or securities that are guaranteed by the United States; or,
Deposited only into accounts that are insured by an agency or instrumentality of the United States or are fully collateralized to ensure protection of the funds, even in the event of a bank failure.
20.205 – Highway Planning and Construction Cluster
Wage Rate Requirements
Compliance Requirements: The Wage Rate Requirements are applicable to construction work on federal-aid highways or on projects using ADHS or FLTTP funds. These requirements apply to federal-aid projects located within the right-of-way of a federal-aid highway. These requirements also apply to federal-aid projects funded by the STBG program that are located outside the right-of-way of a federal-aid highway, including projects funded under the Transportation Alternatives Set-Aside (except for projects funded under the Recreational Trails Program). FHWA has provided guidance on the applicability of these requirements at http://www.fhwa.dot.gov/construction/contracts/080625.cfm (23 USC 113 and 40 U.SC 14701).
Project Approvals
Compliance Requirements: FHWA project approval/authorization to proceed is required before costs are incurred for all phases or projects, except for certain property acquisition costs permitted under 23 USC 108, certain emergency repair work under 23 USC 125, and preliminary engineering under Section 1440 of the FAST Act (23 USC 121 note). Based on the Stewardship and Oversight agreement between the State DOT and the FHWA Division office, projects may be authorized under the authority in 23 USC 106(c), which allows the State DOT to assume responsibilities for designs, plans, specifications, estimates, contract awards, and inspection of progress. When FHWA authorizes a construction project or phase in a project agreement, the State DOT may incur costs; i.e., advertise for bids or use force account work (23 CFR sections 630.205(c), 635.112(a), 635.204, and 635.309).
Condition/Context:
• Management has not implemented an effective internal control system.
• No support was provided to test any special tests or provisions for these programs.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-007.
Recommendation: We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend Joint Programs maintain records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
15.029 – Judicial Services
Investment of Advance Funds
Funds advanced, pending expenditure under this contract, shall be placed in appropriate savings, checking, or investment accounts. Such funds, when invested or deposited, shall be subject to the following:
(a) Invested only in obligations of the United States, or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission and which only invest in obligations of the United States or securities that are guaranteed by the United States; or,
Deposited only into accounts that are insured by an agency or instrumentality of the United States or are fully collateralized to ensure protection of the funds, even in the event of a bank failure.
20.205 – Highway Planning and Construction Cluster
Wage Rate Requirements
Compliance Requirements: The Wage Rate Requirements are applicable to construction work on federal-aid highways or on projects using ADHS or FLTTP funds. These requirements apply to federal-aid projects located within the right-of-way of a federal-aid highway. These requirements also apply to federal-aid projects funded by the STBG program that are located outside the right-of-way of a federal-aid highway, including projects funded under the Transportation Alternatives Set-Aside (except for projects funded under the Recreational Trails Program). FHWA has provided guidance on the applicability of these requirements at http://www.fhwa.dot.gov/construction/contracts/080625.cfm (23 USC 113 and 40 U.SC 14701).
Project Approvals
Compliance Requirements: FHWA project approval/authorization to proceed is required before costs are incurred for all phases or projects, except for certain property acquisition costs permitted under 23 USC 108, certain emergency repair work under 23 USC 125, and preliminary engineering under Section 1440 of the FAST Act (23 USC 121 note). Based on the Stewardship and Oversight agreement between the State DOT and the FHWA Division office, projects may be authorized under the authority in 23 USC 106(c), which allows the State DOT to assume responsibilities for designs, plans, specifications, estimates, contract awards, and inspection of progress. When FHWA authorizes a construction project or phase in a project agreement, the State DOT may incur costs; i.e., advertise for bids or use force account work (23 CFR sections 630.205(c), 635.112(a), 635.204, and 635.309).
Condition/Context:
• Management has not implemented an effective internal control system.
• No support was provided to test any special tests or provisions for these programs.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-007.
Recommendation: We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend Joint Programs maintain records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
15.029 – Judicial Services
Investment of Advance Funds
Funds advanced, pending expenditure under this contract, shall be placed in appropriate savings, checking, or investment accounts. Such funds, when invested or deposited, shall be subject to the following:
(a) Invested only in obligations of the United States, or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission and which only invest in obligations of the United States or securities that are guaranteed by the United States; or,
Deposited only into accounts that are insured by an agency or instrumentality of the United States or are fully collateralized to ensure protection of the funds, even in the event of a bank failure.
20.205 – Highway Planning and Construction Cluster
Wage Rate Requirements
Compliance Requirements: The Wage Rate Requirements are applicable to construction work on federal-aid highways or on projects using ADHS or FLTTP funds. These requirements apply to federal-aid projects located within the right-of-way of a federal-aid highway. These requirements also apply to federal-aid projects funded by the STBG program that are located outside the right-of-way of a federal-aid highway, including projects funded under the Transportation Alternatives Set-Aside (except for projects funded under the Recreational Trails Program). FHWA has provided guidance on the applicability of these requirements at http://www.fhwa.dot.gov/construction/contracts/080625.cfm (23 USC 113 and 40 U.SC 14701).
Project Approvals
Compliance Requirements: FHWA project approval/authorization to proceed is required before costs are incurred for all phases or projects, except for certain property acquisition costs permitted under 23 USC 108, certain emergency repair work under 23 USC 125, and preliminary engineering under Section 1440 of the FAST Act (23 USC 121 note). Based on the Stewardship and Oversight agreement between the State DOT and the FHWA Division office, projects may be authorized under the authority in 23 USC 106(c), which allows the State DOT to assume responsibilities for designs, plans, specifications, estimates, contract awards, and inspection of progress. When FHWA authorizes a construction project or phase in a project agreement, the State DOT may incur costs; i.e., advertise for bids or use force account work (23 CFR sections 630.205(c), 635.112(a), 635.204, and 635.309).
Condition/Context:
• Management has not implemented an effective internal control system.
• No support was provided to test any special tests or provisions for these programs.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-007.
Recommendation: We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend Joint Programs maintain records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
15.029 – Judicial Services
Investment of Advance Funds
Funds advanced, pending expenditure under this contract, shall be placed in appropriate savings, checking, or investment accounts. Such funds, when invested or deposited, shall be subject to the following:
(a) Invested only in obligations of the United States, or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission and which only invest in obligations of the United States or securities that are guaranteed by the United States; or,
Deposited only into accounts that are insured by an agency or instrumentality of the United States or are fully collateralized to ensure protection of the funds, even in the event of a bank failure.
20.205 – Highway Planning and Construction Cluster
Wage Rate Requirements
Compliance Requirements: The Wage Rate Requirements are applicable to construction work on federal-aid highways or on projects using ADHS or FLTTP funds. These requirements apply to federal-aid projects located within the right-of-way of a federal-aid highway. These requirements also apply to federal-aid projects funded by the STBG program that are located outside the right-of-way of a federal-aid highway, including projects funded under the Transportation Alternatives Set-Aside (except for projects funded under the Recreational Trails Program). FHWA has provided guidance on the applicability of these requirements at http://www.fhwa.dot.gov/construction/contracts/080625.cfm (23 USC 113 and 40 U.SC 14701).
Project Approvals
Compliance Requirements: FHWA project approval/authorization to proceed is required before costs are incurred for all phases or projects, except for certain property acquisition costs permitted under 23 USC 108, certain emergency repair work under 23 USC 125, and preliminary engineering under Section 1440 of the FAST Act (23 USC 121 note). Based on the Stewardship and Oversight agreement between the State DOT and the FHWA Division office, projects may be authorized under the authority in 23 USC 106(c), which allows the State DOT to assume responsibilities for designs, plans, specifications, estimates, contract awards, and inspection of progress. When FHWA authorizes a construction project or phase in a project agreement, the State DOT may incur costs; i.e., advertise for bids or use force account work (23 CFR sections 630.205(c), 635.112(a), 635.204, and 635.309).
Condition/Context:
• Management has not implemented an effective internal control system.
• No support was provided to test any special tests or provisions for these programs.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-007.
Recommendation: We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend Joint Programs maintain records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Controls should be in place to ensure that limitations on cash management in federal regulations are adhered to, including ensuring that drawdowns of federal funding are supported by proper documentation and are approved by an appropriate level of management and that Joint Programs maintain a written policy over the payment requests and drawdown of funds.
Condition/Context:
No support was provided for 2 of 2 samples.
[X ] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, controls over cash management were not operating effectively, particularly in ensuring that proper supporting documentation is maintained for drawdowns.
Effect:
Without an effective internal control system, an entity’s objectives in operations, reporting, and compliance cannot be achieved. Additionally, drawdowns and payment requests may have been made without proper supporting documentation.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-002.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Controls should be in place to ensure that limitations on cash management in federal regulations are adhered to, including ensuring that drawdowns of federal funding are supported by proper documentation and are approved by an appropriate level of management and that Joint Programs maintain a written policy over the payment requests and drawdown of funds.
Condition/Context:
No support was provided for 2 of 2 samples.
[X ] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, controls over cash management were not operating effectively, particularly in ensuring that proper supporting documentation is maintained for drawdowns.
Effect:
Without an effective internal control system, an entity’s objectives in operations, reporting, and compliance cannot be achieved. Additionally, drawdowns and payment requests may have been made without proper supporting documentation.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-002.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Controls should be in place to ensure that limitations on cash management in federal regulations are adhered to, including ensuring that drawdowns of federal funding are supported by proper documentation and are approved by an appropriate level of management and that Joint Programs maintain a written policy over the payment requests and drawdown of funds.
Condition/Context:
No support was provided for 2 of 2 samples.
[X ] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, controls over cash management were not operating effectively, particularly in ensuring that proper supporting documentation is maintained for drawdowns.
Effect:
Without an effective internal control system, an entity’s objectives in operations, reporting, and compliance cannot be achieved. Additionally, drawdowns and payment requests may have been made without proper supporting documentation.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-002.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Controls should be in place to ensure that limitations on cash management in federal regulations are adhered to, including ensuring that drawdowns of federal funding are supported by proper documentation and are approved by an appropriate level of management and that Joint Programs maintain a written policy over the payment requests and drawdown of funds.
Condition/Context:
No support was provided for 2 of 2 samples.
[X ] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, controls over cash management were not operating effectively, particularly in ensuring that proper supporting documentation is maintained for drawdowns.
Effect:
Without an effective internal control system, an entity’s objectives in operations, reporting, and compliance cannot be achieved. Additionally, drawdowns and payment requests may have been made without proper supporting documentation.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-002.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Controls should be in place to ensure that limitations on cash management in federal regulations are adhered to, including ensuring that drawdowns of federal funding are supported by proper documentation and are approved by an appropriate level of management and that Joint Programs maintain a written policy over the payment requests and drawdown of funds.
Condition/Context:
No support was provided for 2 of 2 samples.
[X ] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, controls over cash management were not operating effectively, particularly in ensuring that proper supporting documentation is maintained for drawdowns.
Effect:
Without an effective internal control system, an entity’s objectives in operations, reporting, and compliance cannot be achieved. Additionally, drawdowns and payment requests may have been made without proper supporting documentation.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-002.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of federal awards by:
a. States, local governments, and Indian tribes.
b. Institutions of higher education (IHEs).
c. Nonprofit organizations.
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under federal awards;
4. Be accorded consistent treatment. A cost may not be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the federal award as an indirect cost.
7. Be adequately documented.
Condition/Context:
During transactional testing of the Judicial Services (AL #15.029) program, the following were noted:
• 12 of 26 nonpayroll samples did not have proper approvals.
• 3 of 34 payroll samples did not have proper Personnel Status Forms provided.
• 3 of 34 payroll samples did not have proper Timesheet approvals.
• 2 of 34 payroll samples did not have proper pay rate documented.
During transactional testing of the Highway Planning and Construction Cluster (AL #20.205), the following were noted:
• 8 of 8 Individually Important Items (IIIs) did not have all required approvals.
• 11 of 40 non payroll samples did not have all required approvals.
• 20 of 20 payroll samples did not have payrate approval provided.
• 2 of 20 payroll samples did not have an approved timesheet.
• 2 of 40 non payroll samples did not have adequate support provided.
During transactional testing of the Road Maintenance Programs (AL #20.509), the following were noted:
• 1 of 4 IIIs did not have support provided.
• 3 of 4 IIIs did not have proper approvals.
• 39 of 39 non payroll samples did not proper approvals.
• 4 of 21 payroll samples were missing timesheets.
• 2 of 21 payroll samples did not have an accurate Payroll Status Form provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel and lack of internal controls, the entity did not have the ability to provide supporting documentation.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, program funds could be expended on activities or costs that are deemed unallowable by the funding agency.
Questioned Costs:
Known – $32,912 AL # 15.029 – Judicial Services.
Known – $61,693 AL # 20.205 – Highway Planning and Construction Cluster.
Known – $13,275 AL # 20.509 – Road Maintenance Programs.
Repeat Finding:
Yes – 2021-003.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend all records be maintained and filed in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)).
A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)).
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)).
Condition/Context:
Management has not implemented an effective internal control system.
• A physical inventory was taken in 2021 but was not reconciled to the general ledger.
15.029
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
20.205
• A physical inventory was conducted in 2021; however, there were no documented controls over the inventory, and it was not reconciled to the property records.
• 3 of 3 Individually Important Items (IIIs) equipment additions did not have all required approvals.
• 1 of 2 equipment addition samples had no support provided.
• 1 of 2 equipment addition samples did not have all required approvals.
20.509
• A physical inventory was conducted in 2021; however, there were no documented controls over the Inventory, and it was not reconciled to the property records.
• 6 of 6 equipment samples including prior year equipment did not have support provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, property records can be incorrect, and property can be damaged or lost without the knowledge of management.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-004.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. In addition, we recommend that the physical inventory taken is reconciled with the property records at least once every two years.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must:
1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements.
2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319.
3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)).
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215.
When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR Section 180.300).
Condition/Context:
20.205 – Highway Planning and Construction Cluster
• 1 of 8 Individually Important Items (IIIs) had bidding/solicitation documentation but did not have proper approval.
• 2 of 8 IIIs had documentation of one quote obtained but no further documentation.
• 5 of 8 IIIs and 2 of 2 procurement samples had no bidding/solicitation support provided.
• 8 of 8 IIIs and 2 of 2 suspension and debarment samples did not have documentation of a suspension and debarment search prior to payment.
20.509 – Road Maintenance Programs
• 3 of 3 IIIs and 7 of 7 procurement samples had no bidding/solicitation support provided.
• 3 of 3 IIIs and 2 of 2 suspension and debarment samples did not have proper documentation provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, Joint Programs could be subject to questioned costs or other sanctions from funding agencies if they determine that Joint Programs did not assure full and open competition for the procurements and/or if vendors retained and paid from federal funds and are later found to be suspended or debarred.
Questioned Costs:
Known – $971,925 AL# 20.205
Known – $563,676 AL# 20.509
Repeat Finding:
Yes – 2021-005.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend that Joint Programs conduct training for staff to review procurement and suspension and debarment policies and procedures and maintain all records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must:
1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements.
2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319.
3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)).
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215.
When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR Section 180.300).
Condition/Context:
20.205 – Highway Planning and Construction Cluster
• 1 of 8 Individually Important Items (IIIs) had bidding/solicitation documentation but did not have proper approval.
• 2 of 8 IIIs had documentation of one quote obtained but no further documentation.
• 5 of 8 IIIs and 2 of 2 procurement samples had no bidding/solicitation support provided.
• 8 of 8 IIIs and 2 of 2 suspension and debarment samples did not have documentation of a suspension and debarment search prior to payment.
20.509 – Road Maintenance Programs
• 3 of 3 IIIs and 7 of 7 procurement samples had no bidding/solicitation support provided.
• 3 of 3 IIIs and 2 of 2 suspension and debarment samples did not have proper documentation provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, Joint Programs could be subject to questioned costs or other sanctions from funding agencies if they determine that Joint Programs did not assure full and open competition for the procurements and/or if vendors retained and paid from federal funds and are later found to be suspended or debarred.
Questioned Costs:
Known – $971,925 AL# 20.205
Known – $563,676 AL# 20.509
Repeat Finding:
Yes – 2021-005.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend that Joint Programs conduct training for staff to review procurement and suspension and debarment policies and procedures and maintain all records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must:
1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements.
2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319.
3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)).
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215.
When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR Section 180.300).
Condition/Context:
20.205 – Highway Planning and Construction Cluster
• 1 of 8 Individually Important Items (IIIs) had bidding/solicitation documentation but did not have proper approval.
• 2 of 8 IIIs had documentation of one quote obtained but no further documentation.
• 5 of 8 IIIs and 2 of 2 procurement samples had no bidding/solicitation support provided.
• 8 of 8 IIIs and 2 of 2 suspension and debarment samples did not have documentation of a suspension and debarment search prior to payment.
20.509 – Road Maintenance Programs
• 3 of 3 IIIs and 7 of 7 procurement samples had no bidding/solicitation support provided.
• 3 of 3 IIIs and 2 of 2 suspension and debarment samples did not have proper documentation provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, Joint Programs could be subject to questioned costs or other sanctions from funding agencies if they determine that Joint Programs did not assure full and open competition for the procurements and/or if vendors retained and paid from federal funds and are later found to be suspended or debarred.
Questioned Costs:
Known – $971,925 AL# 20.205
Known – $563,676 AL# 20.509
Repeat Finding:
Yes – 2021-005.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend that Joint Programs conduct training for staff to review procurement and suspension and debarment policies and procedures and maintain all records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must:
1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements.
2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319.
3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)).
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215.
When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR Section 180.300).
Condition/Context:
20.205 – Highway Planning and Construction Cluster
• 1 of 8 Individually Important Items (IIIs) had bidding/solicitation documentation but did not have proper approval.
• 2 of 8 IIIs had documentation of one quote obtained but no further documentation.
• 5 of 8 IIIs and 2 of 2 procurement samples had no bidding/solicitation support provided.
• 8 of 8 IIIs and 2 of 2 suspension and debarment samples did not have documentation of a suspension and debarment search prior to payment.
20.509 – Road Maintenance Programs
• 3 of 3 IIIs and 7 of 7 procurement samples had no bidding/solicitation support provided.
• 3 of 3 IIIs and 2 of 2 suspension and debarment samples did not have proper documentation provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, Joint Programs could be subject to questioned costs or other sanctions from funding agencies if they determine that Joint Programs did not assure full and open competition for the procurements and/or if vendors retained and paid from federal funds and are later found to be suspended or debarred.
Questioned Costs:
Known – $971,925 AL# 20.205
Known – $563,676 AL# 20.509
Repeat Finding:
Yes – 2021-005.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend that Joint Programs conduct training for staff to review procurement and suspension and debarment policies and procedures and maintain all records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must:
1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements.
2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319.
3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)).
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215.
When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR Section 180.300).
Condition/Context:
20.205 – Highway Planning and Construction Cluster
• 1 of 8 Individually Important Items (IIIs) had bidding/solicitation documentation but did not have proper approval.
• 2 of 8 IIIs had documentation of one quote obtained but no further documentation.
• 5 of 8 IIIs and 2 of 2 procurement samples had no bidding/solicitation support provided.
• 8 of 8 IIIs and 2 of 2 suspension and debarment samples did not have documentation of a suspension and debarment search prior to payment.
20.509 – Road Maintenance Programs
• 3 of 3 IIIs and 7 of 7 procurement samples had no bidding/solicitation support provided.
• 3 of 3 IIIs and 2 of 2 suspension and debarment samples did not have proper documentation provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, Joint Programs could be subject to questioned costs or other sanctions from funding agencies if they determine that Joint Programs did not assure full and open competition for the procurements and/or if vendors retained and paid from federal funds and are later found to be suspended or debarred.
Questioned Costs:
Known – $971,925 AL# 20.205
Known – $563,676 AL# 20.509
Repeat Finding:
Yes – 2021-005.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend that Joint Programs conduct training for staff to review procurement and suspension and debarment policies and procedures and maintain all records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must:
1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements.
2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319.
3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)).
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215.
When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR Section 180.300).
Condition/Context:
20.205 – Highway Planning and Construction Cluster
• 1 of 8 Individually Important Items (IIIs) had bidding/solicitation documentation but did not have proper approval.
• 2 of 8 IIIs had documentation of one quote obtained but no further documentation.
• 5 of 8 IIIs and 2 of 2 procurement samples had no bidding/solicitation support provided.
• 8 of 8 IIIs and 2 of 2 suspension and debarment samples did not have documentation of a suspension and debarment search prior to payment.
20.509 – Road Maintenance Programs
• 3 of 3 IIIs and 7 of 7 procurement samples had no bidding/solicitation support provided.
• 3 of 3 IIIs and 2 of 2 suspension and debarment samples did not have proper documentation provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, Joint Programs could be subject to questioned costs or other sanctions from funding agencies if they determine that Joint Programs did not assure full and open competition for the procurements and/or if vendors retained and paid from federal funds and are later found to be suspended or debarred.
Questioned Costs:
Known – $971,925 AL# 20.205
Known – $563,676 AL# 20.509
Repeat Finding:
Yes – 2021-005.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend that Joint Programs conduct training for staff to review procurement and suspension and debarment policies and procedures and maintain all records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must:
1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements.
2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319.
3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)).
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215.
When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR Section 180.300).
Condition/Context:
20.205 – Highway Planning and Construction Cluster
• 1 of 8 Individually Important Items (IIIs) had bidding/solicitation documentation but did not have proper approval.
• 2 of 8 IIIs had documentation of one quote obtained but no further documentation.
• 5 of 8 IIIs and 2 of 2 procurement samples had no bidding/solicitation support provided.
• 8 of 8 IIIs and 2 of 2 suspension and debarment samples did not have documentation of a suspension and debarment search prior to payment.
20.509 – Road Maintenance Programs
• 3 of 3 IIIs and 7 of 7 procurement samples had no bidding/solicitation support provided.
• 3 of 3 IIIs and 2 of 2 suspension and debarment samples did not have proper documentation provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, Joint Programs could be subject to questioned costs or other sanctions from funding agencies if they determine that Joint Programs did not assure full and open competition for the procurements and/or if vendors retained and paid from federal funds and are later found to be suspended or debarred.
Questioned Costs:
Known – $971,925 AL# 20.205
Known – $563,676 AL# 20.509
Repeat Finding:
Yes – 2021-005.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend that Joint Programs conduct training for staff to review procurement and suspension and debarment policies and procedures and maintain all records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
AL Number Award Number Award Period Grant Name
20.509 A18AV01093/218AV00785 1/1/2018-9/30/2023 Road Maintenance Programs
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must:
1. Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements.
2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319.
3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)).
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215.
When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR Section 180.300).
Condition/Context:
20.205 – Highway Planning and Construction Cluster
• 1 of 8 Individually Important Items (IIIs) had bidding/solicitation documentation but did not have proper approval.
• 2 of 8 IIIs had documentation of one quote obtained but no further documentation.
• 5 of 8 IIIs and 2 of 2 procurement samples had no bidding/solicitation support provided.
• 8 of 8 IIIs and 2 of 2 suspension and debarment samples did not have documentation of a suspension and debarment search prior to payment.
20.509 – Road Maintenance Programs
• 3 of 3 IIIs and 7 of 7 procurement samples had no bidding/solicitation support provided.
• 3 of 3 IIIs and 2 of 2 suspension and debarment samples did not have proper documentation provided.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. In addition, Joint Programs could be subject to questioned costs or other sanctions from funding agencies if they determine that Joint Programs did not assure full and open competition for the procurements and/or if vendors retained and paid from federal funds and are later found to be suspended or debarred.
Questioned Costs:
Known – $971,925 AL# 20.205
Known – $563,676 AL# 20.509
Repeat Finding:
Yes – 2021-005.
Recommendation:
We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend that Joint Programs conduct training for staff to review procurement and suspension and debarment policies and procedures and maintain all records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Reporting requirements are contained in the following:
Financial reporting, 2 CFR section 200.328.
Monitoring and reporting program performance, 2 CFR section 200.329.
Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation.
Condition/Context:
15.029 – Judicial Services
Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports.
20.205 – Highway Planning and Construction Cluster
Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-006.
Recommendation:
Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Reporting requirements are contained in the following:
Financial reporting, 2 CFR section 200.328.
Monitoring and reporting program performance, 2 CFR section 200.329.
Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation.
Condition/Context:
15.029 – Judicial Services
Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports.
20.205 – Highway Planning and Construction Cluster
Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-006.
Recommendation:
Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Reporting requirements are contained in the following:
Financial reporting, 2 CFR section 200.328.
Monitoring and reporting program performance, 2 CFR section 200.329.
Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation.
Condition/Context:
15.029 – Judicial Services
Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports.
20.205 – Highway Planning and Construction Cluster
Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-006.
Recommendation:
Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Reporting requirements are contained in the following:
Financial reporting, 2 CFR section 200.328.
Monitoring and reporting program performance, 2 CFR section 200.329.
Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation.
Condition/Context:
15.029 – Judicial Services
Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports.
20.205 – Highway Planning and Construction Cluster
Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-006.
Recommendation:
Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Reporting requirements are contained in the following:
Financial reporting, 2 CFR section 200.328.
Monitoring and reporting program performance, 2 CFR section 200.329.
Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation.
Condition/Context:
15.029 – Judicial Services
Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports.
20.205 – Highway Planning and Construction Cluster
Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-006.
Recommendation:
Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Reporting requirements are contained in the following:
Financial reporting, 2 CFR section 200.328.
Monitoring and reporting program performance, 2 CFR section 200.329.
Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation.
Condition/Context:
15.029 – Judicial Services
Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports.
20.205 – Highway Planning and Construction Cluster
Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-006.
Recommendation:
Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Reporting requirements are contained in the following:
Financial reporting, 2 CFR section 200.328.
Monitoring and reporting program performance, 2 CFR section 200.329.
Federal regulations and grant/contract conditions require financial and programmatic reports to be filed in a timely manner and should be supported by accurate supporting documentation.
Condition/Context:
15.029 – Judicial Services
Management has not implemented an effective internal control system for reporting. We were not provided the FY2022 Annual Narrative Report or FY2022 Quarterly SF-425 Federal Financial Reports.
20.205 – Highway Planning and Construction Cluster
Management has not implemented an effective internal control system for reporting. We were not provided 1 of 1 required PR-20 Voucher for Work Under Provisions of the Federal-Aid and Federal Highway Acts Report.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Policies and procedures have not been implemented properly to ensure compliance with federal reporting requirements. Further, Joint Programs did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported.
Effect:
Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Additionally, Joint Programs is out of compliance with federal reporting requirements for the above programs and amounts reported to federal agencies may be inaccurate.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-006.
Recommendation:
Joint Programs should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
15.029 – Judicial Services
Investment of Advance Funds
Funds advanced, pending expenditure under this contract, shall be placed in appropriate savings, checking, or investment accounts. Such funds, when invested or deposited, shall be subject to the following:
(a) Invested only in obligations of the United States, or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission and which only invest in obligations of the United States or securities that are guaranteed by the United States; or,
Deposited only into accounts that are insured by an agency or instrumentality of the United States or are fully collateralized to ensure protection of the funds, even in the event of a bank failure.
20.205 – Highway Planning and Construction Cluster
Wage Rate Requirements
Compliance Requirements: The Wage Rate Requirements are applicable to construction work on federal-aid highways or on projects using ADHS or FLTTP funds. These requirements apply to federal-aid projects located within the right-of-way of a federal-aid highway. These requirements also apply to federal-aid projects funded by the STBG program that are located outside the right-of-way of a federal-aid highway, including projects funded under the Transportation Alternatives Set-Aside (except for projects funded under the Recreational Trails Program). FHWA has provided guidance on the applicability of these requirements at http://www.fhwa.dot.gov/construction/contracts/080625.cfm (23 USC 113 and 40 U.SC 14701).
Project Approvals
Compliance Requirements: FHWA project approval/authorization to proceed is required before costs are incurred for all phases or projects, except for certain property acquisition costs permitted under 23 USC 108, certain emergency repair work under 23 USC 125, and preliminary engineering under Section 1440 of the FAST Act (23 USC 121 note). Based on the Stewardship and Oversight agreement between the State DOT and the FHWA Division office, projects may be authorized under the authority in 23 USC 106(c), which allows the State DOT to assume responsibilities for designs, plans, specifications, estimates, contract awards, and inspection of progress. When FHWA authorizes a construction project or phase in a project agreement, the State DOT may incur costs; i.e., advertise for bids or use force account work (23 CFR sections 630.205(c), 635.112(a), 635.204, and 635.309).
Condition/Context:
• Management has not implemented an effective internal control system.
• No support was provided to test any special tests or provisions for these programs.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-007.
Recommendation: We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend Joint Programs maintain records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
15.029 – Judicial Services
Investment of Advance Funds
Funds advanced, pending expenditure under this contract, shall be placed in appropriate savings, checking, or investment accounts. Such funds, when invested or deposited, shall be subject to the following:
(a) Invested only in obligations of the United States, or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission and which only invest in obligations of the United States or securities that are guaranteed by the United States; or,
Deposited only into accounts that are insured by an agency or instrumentality of the United States or are fully collateralized to ensure protection of the funds, even in the event of a bank failure.
20.205 – Highway Planning and Construction Cluster
Wage Rate Requirements
Compliance Requirements: The Wage Rate Requirements are applicable to construction work on federal-aid highways or on projects using ADHS or FLTTP funds. These requirements apply to federal-aid projects located within the right-of-way of a federal-aid highway. These requirements also apply to federal-aid projects funded by the STBG program that are located outside the right-of-way of a federal-aid highway, including projects funded under the Transportation Alternatives Set-Aside (except for projects funded under the Recreational Trails Program). FHWA has provided guidance on the applicability of these requirements at http://www.fhwa.dot.gov/construction/contracts/080625.cfm (23 USC 113 and 40 U.SC 14701).
Project Approvals
Compliance Requirements: FHWA project approval/authorization to proceed is required before costs are incurred for all phases or projects, except for certain property acquisition costs permitted under 23 USC 108, certain emergency repair work under 23 USC 125, and preliminary engineering under Section 1440 of the FAST Act (23 USC 121 note). Based on the Stewardship and Oversight agreement between the State DOT and the FHWA Division office, projects may be authorized under the authority in 23 USC 106(c), which allows the State DOT to assume responsibilities for designs, plans, specifications, estimates, contract awards, and inspection of progress. When FHWA authorizes a construction project or phase in a project agreement, the State DOT may incur costs; i.e., advertise for bids or use force account work (23 CFR sections 630.205(c), 635.112(a), 635.204, and 635.309).
Condition/Context:
• Management has not implemented an effective internal control system.
• No support was provided to test any special tests or provisions for these programs.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-007.
Recommendation: We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend Joint Programs maintain records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
15.029 – Judicial Services
Investment of Advance Funds
Funds advanced, pending expenditure under this contract, shall be placed in appropriate savings, checking, or investment accounts. Such funds, when invested or deposited, shall be subject to the following:
(a) Invested only in obligations of the United States, or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission and which only invest in obligations of the United States or securities that are guaranteed by the United States; or,
Deposited only into accounts that are insured by an agency or instrumentality of the United States or are fully collateralized to ensure protection of the funds, even in the event of a bank failure.
20.205 – Highway Planning and Construction Cluster
Wage Rate Requirements
Compliance Requirements: The Wage Rate Requirements are applicable to construction work on federal-aid highways or on projects using ADHS or FLTTP funds. These requirements apply to federal-aid projects located within the right-of-way of a federal-aid highway. These requirements also apply to federal-aid projects funded by the STBG program that are located outside the right-of-way of a federal-aid highway, including projects funded under the Transportation Alternatives Set-Aside (except for projects funded under the Recreational Trails Program). FHWA has provided guidance on the applicability of these requirements at http://www.fhwa.dot.gov/construction/contracts/080625.cfm (23 USC 113 and 40 U.SC 14701).
Project Approvals
Compliance Requirements: FHWA project approval/authorization to proceed is required before costs are incurred for all phases or projects, except for certain property acquisition costs permitted under 23 USC 108, certain emergency repair work under 23 USC 125, and preliminary engineering under Section 1440 of the FAST Act (23 USC 121 note). Based on the Stewardship and Oversight agreement between the State DOT and the FHWA Division office, projects may be authorized under the authority in 23 USC 106(c), which allows the State DOT to assume responsibilities for designs, plans, specifications, estimates, contract awards, and inspection of progress. When FHWA authorizes a construction project or phase in a project agreement, the State DOT may incur costs; i.e., advertise for bids or use force account work (23 CFR sections 630.205(c), 635.112(a), 635.204, and 635.309).
Condition/Context:
• Management has not implemented an effective internal control system.
• No support was provided to test any special tests or provisions for these programs.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-007.
Recommendation: We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend Joint Programs maintain records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
15.029 – Judicial Services
Investment of Advance Funds
Funds advanced, pending expenditure under this contract, shall be placed in appropriate savings, checking, or investment accounts. Such funds, when invested or deposited, shall be subject to the following:
(a) Invested only in obligations of the United States, or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission and which only invest in obligations of the United States or securities that are guaranteed by the United States; or,
Deposited only into accounts that are insured by an agency or instrumentality of the United States or are fully collateralized to ensure protection of the funds, even in the event of a bank failure.
20.205 – Highway Planning and Construction Cluster
Wage Rate Requirements
Compliance Requirements: The Wage Rate Requirements are applicable to construction work on federal-aid highways or on projects using ADHS or FLTTP funds. These requirements apply to federal-aid projects located within the right-of-way of a federal-aid highway. These requirements also apply to federal-aid projects funded by the STBG program that are located outside the right-of-way of a federal-aid highway, including projects funded under the Transportation Alternatives Set-Aside (except for projects funded under the Recreational Trails Program). FHWA has provided guidance on the applicability of these requirements at http://www.fhwa.dot.gov/construction/contracts/080625.cfm (23 USC 113 and 40 U.SC 14701).
Project Approvals
Compliance Requirements: FHWA project approval/authorization to proceed is required before costs are incurred for all phases or projects, except for certain property acquisition costs permitted under 23 USC 108, certain emergency repair work under 23 USC 125, and preliminary engineering under Section 1440 of the FAST Act (23 USC 121 note). Based on the Stewardship and Oversight agreement between the State DOT and the FHWA Division office, projects may be authorized under the authority in 23 USC 106(c), which allows the State DOT to assume responsibilities for designs, plans, specifications, estimates, contract awards, and inspection of progress. When FHWA authorizes a construction project or phase in a project agreement, the State DOT may incur costs; i.e., advertise for bids or use force account work (23 CFR sections 630.205(c), 635.112(a), 635.204, and 635.309).
Condition/Context:
• Management has not implemented an effective internal control system.
• No support was provided to test any special tests or provisions for these programs.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-007.
Recommendation: We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend Joint Programs maintain records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
15.029 – Judicial Services
Investment of Advance Funds
Funds advanced, pending expenditure under this contract, shall be placed in appropriate savings, checking, or investment accounts. Such funds, when invested or deposited, shall be subject to the following:
(a) Invested only in obligations of the United States, or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission and which only invest in obligations of the United States or securities that are guaranteed by the United States; or,
Deposited only into accounts that are insured by an agency or instrumentality of the United States or are fully collateralized to ensure protection of the funds, even in the event of a bank failure.
20.205 – Highway Planning and Construction Cluster
Wage Rate Requirements
Compliance Requirements: The Wage Rate Requirements are applicable to construction work on federal-aid highways or on projects using ADHS or FLTTP funds. These requirements apply to federal-aid projects located within the right-of-way of a federal-aid highway. These requirements also apply to federal-aid projects funded by the STBG program that are located outside the right-of-way of a federal-aid highway, including projects funded under the Transportation Alternatives Set-Aside (except for projects funded under the Recreational Trails Program). FHWA has provided guidance on the applicability of these requirements at http://www.fhwa.dot.gov/construction/contracts/080625.cfm (23 USC 113 and 40 U.SC 14701).
Project Approvals
Compliance Requirements: FHWA project approval/authorization to proceed is required before costs are incurred for all phases or projects, except for certain property acquisition costs permitted under 23 USC 108, certain emergency repair work under 23 USC 125, and preliminary engineering under Section 1440 of the FAST Act (23 USC 121 note). Based on the Stewardship and Oversight agreement between the State DOT and the FHWA Division office, projects may be authorized under the authority in 23 USC 106(c), which allows the State DOT to assume responsibilities for designs, plans, specifications, estimates, contract awards, and inspection of progress. When FHWA authorizes a construction project or phase in a project agreement, the State DOT may incur costs; i.e., advertise for bids or use force account work (23 CFR sections 630.205(c), 635.112(a), 635.204, and 635.309).
Condition/Context:
• Management has not implemented an effective internal control system.
• No support was provided to test any special tests or provisions for these programs.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-007.
Recommendation: We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend Joint Programs maintain records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
15.029 – Judicial Services
Investment of Advance Funds
Funds advanced, pending expenditure under this contract, shall be placed in appropriate savings, checking, or investment accounts. Such funds, when invested or deposited, shall be subject to the following:
(a) Invested only in obligations of the United States, or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission and which only invest in obligations of the United States or securities that are guaranteed by the United States; or,
Deposited only into accounts that are insured by an agency or instrumentality of the United States or are fully collateralized to ensure protection of the funds, even in the event of a bank failure.
20.205 – Highway Planning and Construction Cluster
Wage Rate Requirements
Compliance Requirements: The Wage Rate Requirements are applicable to construction work on federal-aid highways or on projects using ADHS or FLTTP funds. These requirements apply to federal-aid projects located within the right-of-way of a federal-aid highway. These requirements also apply to federal-aid projects funded by the STBG program that are located outside the right-of-way of a federal-aid highway, including projects funded under the Transportation Alternatives Set-Aside (except for projects funded under the Recreational Trails Program). FHWA has provided guidance on the applicability of these requirements at http://www.fhwa.dot.gov/construction/contracts/080625.cfm (23 USC 113 and 40 U.SC 14701).
Project Approvals
Compliance Requirements: FHWA project approval/authorization to proceed is required before costs are incurred for all phases or projects, except for certain property acquisition costs permitted under 23 USC 108, certain emergency repair work under 23 USC 125, and preliminary engineering under Section 1440 of the FAST Act (23 USC 121 note). Based on the Stewardship and Oversight agreement between the State DOT and the FHWA Division office, projects may be authorized under the authority in 23 USC 106(c), which allows the State DOT to assume responsibilities for designs, plans, specifications, estimates, contract awards, and inspection of progress. When FHWA authorizes a construction project or phase in a project agreement, the State DOT may incur costs; i.e., advertise for bids or use force account work (23 CFR sections 630.205(c), 635.112(a), 635.204, and 635.309).
Condition/Context:
• Management has not implemented an effective internal control system.
• No support was provided to test any special tests or provisions for these programs.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-007.
Recommendation: We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend Joint Programs maintain records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information:
U.S. Department of the Interior
AL Number Award Number Award Period Grant Name
15.029 A21AV00088 10/1/2020-9/30/2023 Judicial Services
U.S. Department of Transportation
AL Number Award Number Award Period Grant Name
20.205 A18AV01093/A17AV00612 1/1/2018-12/31/2022 Highway Planning and Construction Cluster
Criteria:
Per 2 CFR § 200.303 Internal controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
15.029 – Judicial Services
Investment of Advance Funds
Funds advanced, pending expenditure under this contract, shall be placed in appropriate savings, checking, or investment accounts. Such funds, when invested or deposited, shall be subject to the following:
(a) Invested only in obligations of the United States, or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission and which only invest in obligations of the United States or securities that are guaranteed by the United States; or,
Deposited only into accounts that are insured by an agency or instrumentality of the United States or are fully collateralized to ensure protection of the funds, even in the event of a bank failure.
20.205 – Highway Planning and Construction Cluster
Wage Rate Requirements
Compliance Requirements: The Wage Rate Requirements are applicable to construction work on federal-aid highways or on projects using ADHS or FLTTP funds. These requirements apply to federal-aid projects located within the right-of-way of a federal-aid highway. These requirements also apply to federal-aid projects funded by the STBG program that are located outside the right-of-way of a federal-aid highway, including projects funded under the Transportation Alternatives Set-Aside (except for projects funded under the Recreational Trails Program). FHWA has provided guidance on the applicability of these requirements at http://www.fhwa.dot.gov/construction/contracts/080625.cfm (23 USC 113 and 40 U.SC 14701).
Project Approvals
Compliance Requirements: FHWA project approval/authorization to proceed is required before costs are incurred for all phases or projects, except for certain property acquisition costs permitted under 23 USC 108, certain emergency repair work under 23 USC 125, and preliminary engineering under Section 1440 of the FAST Act (23 USC 121 note). Based on the Stewardship and Oversight agreement between the State DOT and the FHWA Division office, projects may be authorized under the authority in 23 USC 106(c), which allows the State DOT to assume responsibilities for designs, plans, specifications, estimates, contract awards, and inspection of progress. When FHWA authorizes a construction project or phase in a project agreement, the State DOT may incur costs; i.e., advertise for bids or use force account work (23 CFR sections 630.205(c), 635.112(a), 635.204, and 635.309).
Condition/Context:
• Management has not implemented an effective internal control system.
• No support was provided to test any special tests or provisions for these programs.
[X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Cause:
Due to turnover in key personnel, Joint Programs had a breakdown in internal controls during 2022.
Effect:
Without an effective internal control system, an entity’s objective: operations, reporting, and compliance cannot be achieved.
Questioned Costs:
Due to lack of sufficient documentation, we were unable to determine questioned costs.
Repeat Finding:
Yes – 2021-007.
Recommendation: We recommend that Joint Programs use the Green Book to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. We also recommend Joint Programs maintain records in a way that allows them to be located and reviewed at any point in time.
View of Responsible Officials and Planned Corrective Action:
Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.