Finding 2024-010 – Lack of County-Wide Internal Controls Over Major Federal Program – Highway
Planning and Construction Cluster (Federal-Aid Highway Program)
PASS-THROUGH GRANTOR: Bureau of Indian Affairs FEDERAL AGENCY: U.S. Department of Transportation
ASSISTANCE LISTING: 20.205
FEDERAL PROGRAM NAME: Highway Planning and Construction Cluster (Federal-Aid Highway Program)
FEDERAL AWARD YEAR: 2019
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Matching;
Procurement and Suspension and Debarment; Special Tests and Provisions
QUESTIONED COSTS: $-0-
Condition: County-wide internal controls regarding Control Environment, Risk Assessment,
Information and Communication, and Monitoring have not been designed.
Cause of Condition: Policies and procedures have not been designed and implemented to ensure the
County complies with grant requirements.
Effect of Condition: This condition could result in noncompliance with grant requirements and could
result in loss of federal funds to the County.
Recommendation: OSAI recommends the County implement a system of internal controls to ensure
compliance with grant requirements.
Management Response:
Chairman of the Board of County Commissioners: We will work to implement a Risk Assessment plan
over federal grants. We will implement controls to make sure we comply with grant requirements and
that federal funds are expended in accordance with grant agreements and in a timely manner. We will
ensure employees have the current and correct compliance supplement to work from.
Criteria: The GAO Standards – Section 1 – Fundamental Concepts of Internal Control – OV1.01 states
in part:
Definition of Internal Control
Internal control is a process effected by an entity’s oversight body, management, and other
personnel that provides reasonable assurance that the objectives of an entity will be achieved.
Additionally, GAO Standards – Section 2 – Establishing an Effective Internal Control System –
OV2.04 states in part:
Components, Principles, and Attributes
Control Environment - The foundation for an internal control system. It provides the discipline and
structure to help an entity achieve its objectives.
Risk Assessment - Assesses the risks facing the entity as it seeks to achieve its objectives. This
assessment provides the basis for developing appropriate risk responses.
Information and Communication - The quality information management and personnel communicate and
use to support the internal control system.
Monitoring - Activities management establishes and operates to assess the quality of
performance over time and promptly resolve the findings of audits and other reviews.
Finding 2024-012 – Lack of Internal Controls Over Major Federal Programs – Highway Planning
and Construction Cluster (Federal-Aid Highway Program)
PASS-THROUGH GRANTOR: Bureau of Indian Affairs FEDERAL AGENCY: U.S. Department of Transportation
ASSISTANCE LISTING: 20.205
FEDERAL PROGRAM NAME: Highway Planning and Construction Cluster (Federal-Aid Highway Program)
FEDERAL AWARD YEAR: 2019
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Matching;
Procurement and Suspension and Debarment; Special Tests and Provisions
QUESTIONED COSTS: $-0-
Condition: During the process of documenting the County’s internal controls regarding federal
disbursements, we noted that the County has not established procedures to ensure compliance with
the following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/Cost
Principles; Matching; Procurement and Suspension and Debarment; Special Tests and Provisions.
Cause of Condition: Policies and procedures have not been designed and implemented to ensure
federal expenditures are made in accordance with federal compliance requirements.
Effect of Condition: This condition could result in noncompliance with grant requirements and could
result in a loss of federal funds to the County.
Recommendation: OSAI recommends the County gain an understanding of requirements for this program
and implement internal control procedures to ensure compliance with requirements.
Management Response:
Chairman of the Board of County Commissioners: The Board of County Commissioners will work with all
County Officials to go over all grants and federal monies that the County receives to ensure that
proper internal controls are implemented.
Criteria: OMB 2 CFR 200, Subpart D. 200.303(a) reads as follows: Subpart D-Post Federal Award
Requirements
§200.303 Internal Controls The non-Federal entity must:
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).
Further, accountability and stewardship should be overall goals in management's accounting of
federal funds. Internal controls should be designed to monitor compliance with laws and regulations
pertaining to grant contracts.
Finding 2024-013 – Lack of County-Wide Internal Controls Over Major Federal Program -
Coronavirus State and Local Fiscal Recovery Funds
PASS-THROUGH GRANTOR: Direct Grant
FEDERAL AGENCY: U.S. Department of Treasury
ASSISTANCE LISTING: 21.027
FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds
FEDERAL AWARD YEAR: 2021
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of
Performance; Procurement and Suspension and Debarment; Reporting; Subrecipient Monitoring
QUESTIONED COSTS: $-0-
Condition: County-wide internal controls regarding Control Environment, Risk Assessment,
Information and Communication, and Monitoring have not been designed.
Cause of Condition: Policies and procedures have not been designed and implemented to ensure the
County complies with grant requirements.
Effect of Condition: This condition could result in noncompliance with grant requirements and could
result in loss of federal funds to the County.
Recommendation: OSAI recommends the County implement a system of internal controls to ensure
compliance with grant requirements.
Management Response:
Chairman of the Board of County Commissioners: We will work to implement a Risk Assessment plan
over federal grants. We will implement controls to make sure we comply with grant requirements and
that federal funds are expended in accordance with grant agreements and in a timely manner. We will
ensure employees have the current and correct compliance supplement to work from.
Criteria: The GAO Standards – Section 1 – Fundamental Concepts of Internal Control – OV1.01 states
in part:
Definition of Internal Control
Internal control is a process effected by an entity’s oversight body, management, and other
personnel that provides reasonable assurance that the objectives of an entity will be achieved.
Additionally, GAO Standards – Section 2 – Establishing an Effective Internal Control System –
OV2.04 states in part:
Components, Principles, and Attributes
Control Environment - The foundation for an internal control system. It provides the discipline and
structure to help an entity achieve its objectives.
Risk Assessment - Assesses the risks facing the entity as it seeks to achieve its objectives. This
assessment provides the basis for developing appropriate risk responses.
Information and Communication - The quality information management and personnel communicate and
use to support the internal control system.
Monitoring - Activities management establishes and operates to assess the quality of
performance over time and promptly resolve the findings of audits and other reviews.
Finding 2024-014 – Lack of Internal Controls Over Major Federal Programs – Coronavirus State
and Local Fiscal Recovery Funds
PASS-THROUGH GRANTOR: Direct Grant
FEDERAL AGENCY: U.S. Department of Treasury
ASSISTANCE LISTING: 21.027
FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds
FEDERAL AWARD YEAR: 2021
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of
Performance; Procurement and Suspension and Debarment; Reporting; Subrecipient Monitoring
QUESTIONED COSTS: $-0-
Condition: During the process of documenting the County’s internal controls regarding federal
disbursements, we noted that the County has not established procedures to ensure compliance with
the following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/Cost
Principles; Period of Performance; Procurement and Suspension and Debarment; Reporting;
Subrecipient Monitoring.
Cause of Condition: Policies and procedures have not been designed and implemented to ensure
federal expenditures are made in accordance with federal compliance requirements.
Effect of Condition: This condition could result in noncompliance with grant requirements and loss
of federal funds to the County.
Recommendation: OSAI recommends the County gain an understanding of requirements for this program
and implement internal control procedures to ensure compliance with requirements.
Management Response:
Chairman of the Board of County Commissioners: The Board of County Commissioners will work with all
County Officials to go over all grants and federal monies that the County receives to ensure that
proper internal controls are implemented.
Criteria: OMB 2 CFR 200, Subpart D. 200.303(a) reads as follows: Subpart D-Post Federal Award
Requirements §200.303 Internal Controls The non-Federal entity must:
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).
Further, accountability and stewardship should be overall goals in management's accounting of
federal funds. Internal controls should be designed to monitor compliance with laws and regulations
pertaining to grant contracts.
Finding 2024-010 – Lack of County-Wide Internal Controls Over Major Federal Program – Highway
Planning and Construction Cluster (Federal-Aid Highway Program)
PASS-THROUGH GRANTOR: Bureau of Indian Affairs FEDERAL AGENCY: U.S. Department of Transportation
ASSISTANCE LISTING: 20.205
FEDERAL PROGRAM NAME: Highway Planning and Construction Cluster (Federal-Aid Highway Program)
FEDERAL AWARD YEAR: 2019
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Matching;
Procurement and Suspension and Debarment; Special Tests and Provisions
QUESTIONED COSTS: $-0-
Condition: County-wide internal controls regarding Control Environment, Risk Assessment,
Information and Communication, and Monitoring have not been designed.
Cause of Condition: Policies and procedures have not been designed and implemented to ensure the
County complies with grant requirements.
Effect of Condition: This condition could result in noncompliance with grant requirements and could
result in loss of federal funds to the County.
Recommendation: OSAI recommends the County implement a system of internal controls to ensure
compliance with grant requirements.
Management Response:
Chairman of the Board of County Commissioners: We will work to implement a Risk Assessment plan
over federal grants. We will implement controls to make sure we comply with grant requirements and
that federal funds are expended in accordance with grant agreements and in a timely manner. We will
ensure employees have the current and correct compliance supplement to work from.
Criteria: The GAO Standards – Section 1 – Fundamental Concepts of Internal Control – OV1.01 states
in part:
Definition of Internal Control
Internal control is a process effected by an entity’s oversight body, management, and other
personnel that provides reasonable assurance that the objectives of an entity will be achieved.
Additionally, GAO Standards – Section 2 – Establishing an Effective Internal Control System –
OV2.04 states in part:
Components, Principles, and Attributes
Control Environment - The foundation for an internal control system. It provides the discipline and
structure to help an entity achieve its objectives.
Risk Assessment - Assesses the risks facing the entity as it seeks to achieve its objectives. This
assessment provides the basis for developing appropriate risk responses.
Information and Communication - The quality information management and personnel communicate and
use to support the internal control system.
Monitoring - Activities management establishes and operates to assess the quality of
performance over time and promptly resolve the findings of audits and other reviews.
Finding 2024-012 – Lack of Internal Controls Over Major Federal Programs – Highway Planning
and Construction Cluster (Federal-Aid Highway Program)
PASS-THROUGH GRANTOR: Bureau of Indian Affairs FEDERAL AGENCY: U.S. Department of Transportation
ASSISTANCE LISTING: 20.205
FEDERAL PROGRAM NAME: Highway Planning and Construction Cluster (Federal-Aid Highway Program)
FEDERAL AWARD YEAR: 2019
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Matching;
Procurement and Suspension and Debarment; Special Tests and Provisions
QUESTIONED COSTS: $-0-
Condition: During the process of documenting the County’s internal controls regarding federal
disbursements, we noted that the County has not established procedures to ensure compliance with
the following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/Cost
Principles; Matching; Procurement and Suspension and Debarment; Special Tests and Provisions.
Cause of Condition: Policies and procedures have not been designed and implemented to ensure
federal expenditures are made in accordance with federal compliance requirements.
Effect of Condition: This condition could result in noncompliance with grant requirements and could
result in a loss of federal funds to the County.
Recommendation: OSAI recommends the County gain an understanding of requirements for this program
and implement internal control procedures to ensure compliance with requirements.
Management Response:
Chairman of the Board of County Commissioners: The Board of County Commissioners will work with all
County Officials to go over all grants and federal monies that the County receives to ensure that
proper internal controls are implemented.
Criteria: OMB 2 CFR 200, Subpart D. 200.303(a) reads as follows: Subpart D-Post Federal Award
Requirements
§200.303 Internal Controls The non-Federal entity must:
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).
Further, accountability and stewardship should be overall goals in management's accounting of
federal funds. Internal controls should be designed to monitor compliance with laws and regulations
pertaining to grant contracts.
Finding 2024-013 – Lack of County-Wide Internal Controls Over Major Federal Program -
Coronavirus State and Local Fiscal Recovery Funds
PASS-THROUGH GRANTOR: Direct Grant
FEDERAL AGENCY: U.S. Department of Treasury
ASSISTANCE LISTING: 21.027
FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds
FEDERAL AWARD YEAR: 2021
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of
Performance; Procurement and Suspension and Debarment; Reporting; Subrecipient Monitoring
QUESTIONED COSTS: $-0-
Condition: County-wide internal controls regarding Control Environment, Risk Assessment,
Information and Communication, and Monitoring have not been designed.
Cause of Condition: Policies and procedures have not been designed and implemented to ensure the
County complies with grant requirements.
Effect of Condition: This condition could result in noncompliance with grant requirements and could
result in loss of federal funds to the County.
Recommendation: OSAI recommends the County implement a system of internal controls to ensure
compliance with grant requirements.
Management Response:
Chairman of the Board of County Commissioners: We will work to implement a Risk Assessment plan
over federal grants. We will implement controls to make sure we comply with grant requirements and
that federal funds are expended in accordance with grant agreements and in a timely manner. We will
ensure employees have the current and correct compliance supplement to work from.
Criteria: The GAO Standards – Section 1 – Fundamental Concepts of Internal Control – OV1.01 states
in part:
Definition of Internal Control
Internal control is a process effected by an entity’s oversight body, management, and other
personnel that provides reasonable assurance that the objectives of an entity will be achieved.
Additionally, GAO Standards – Section 2 – Establishing an Effective Internal Control System –
OV2.04 states in part:
Components, Principles, and Attributes
Control Environment - The foundation for an internal control system. It provides the discipline and
structure to help an entity achieve its objectives.
Risk Assessment - Assesses the risks facing the entity as it seeks to achieve its objectives. This
assessment provides the basis for developing appropriate risk responses.
Information and Communication - The quality information management and personnel communicate and
use to support the internal control system.
Monitoring - Activities management establishes and operates to assess the quality of
performance over time and promptly resolve the findings of audits and other reviews.
Finding 2024-014 – Lack of Internal Controls Over Major Federal Programs – Coronavirus State
and Local Fiscal Recovery Funds
PASS-THROUGH GRANTOR: Direct Grant
FEDERAL AGENCY: U.S. Department of Treasury
ASSISTANCE LISTING: 21.027
FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds
FEDERAL AWARD YEAR: 2021
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of
Performance; Procurement and Suspension and Debarment; Reporting; Subrecipient Monitoring
QUESTIONED COSTS: $-0-
Condition: During the process of documenting the County’s internal controls regarding federal
disbursements, we noted that the County has not established procedures to ensure compliance with
the following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/Cost
Principles; Period of Performance; Procurement and Suspension and Debarment; Reporting;
Subrecipient Monitoring.
Cause of Condition: Policies and procedures have not been designed and implemented to ensure
federal expenditures are made in accordance with federal compliance requirements.
Effect of Condition: This condition could result in noncompliance with grant requirements and loss
of federal funds to the County.
Recommendation: OSAI recommends the County gain an understanding of requirements for this program
and implement internal control procedures to ensure compliance with requirements.
Management Response:
Chairman of the Board of County Commissioners: The Board of County Commissioners will work with all
County Officials to go over all grants and federal monies that the County receives to ensure that
proper internal controls are implemented.
Criteria: OMB 2 CFR 200, Subpart D. 200.303(a) reads as follows: Subpart D-Post Federal Award
Requirements §200.303 Internal Controls The non-Federal entity must:
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).
Further, accountability and stewardship should be overall goals in management's accounting of
federal funds. Internal controls should be designed to monitor compliance with laws and regulations
pertaining to grant contracts.