Federal Grantor: All Programs Pass-through Grantor: All Programs Assistance Listing No.: All Programs Program Title: All Programs Criteria: Title 2 U.S. Code of Federal Regulations Part 200.510(b) requires auditees to prepare a schedule of expenditures of federal awards which must report total federal awards expended during the audit period. At a minimum, the schedule must include: expenditures by individual program, program title and assistance listing number, programs required to be identified as part of a cluster, name of the pass-through entity and identifying number assigned by the pass-through entity for awards not received directly from the federal government, and the total amount provided to subrecipients from each federal program. Condition: The schedule of expenditures of federal awards (SEFA) reported by the County in the annual budget documents contained errors in amounts of federal expenditures reported. Additionally, the schedule did not include the identification of programs required to be part of a cluster, names of pass-through entities, identifying numbers assigned by the pass-through entities, or total amounts provided to subrecipients for the applicable programs. Furthermore, the SEFA prepared by the County does not indicate the amount of awards passed through to subrecipients. The County reported $87,238 in expenditures under assistance listing number 12.112 - Payments to States in Lieu of Real Estate Taxes. All funds expended under this program were disbursed to local schools and road districts, however, these awards to subrecipients were not reported on the SEFA. The County omitted all funds expended under assistance listing number 15.226 - Payments in Lieu of Taxes. The County reported total expenditures of $90,765 under assistance listing number 15.438 - National Forest Acquire Lands. However, $79,432 of this amount was expended under assistance listing number 10.665 - Schools and Roads - Grants to States and $11,333 of this amount was expended under assistance listing number 15.438 - National Forest Acquired Lands. All funds expended under these two programs were disbursed to local schools and road districts, however, these awards to subrecipients were not reported on the SEFA. The County omitted all funds expended under assistance listing number 15.608 - Fish and Aquatic Conservation - Aquatic Invasive Species. The County reported $32,184 in expenditures under assistance listing number 20.205 - Highway Planning and Construction, however, underlying accounting records support expenditures of $33,136. The County reported $2,295,038 in expenditures under assistance listing number 21.027 - COVID-19 Coronavirus State and Local Fiscal Recovery Funds, however, the underlying accounting records support expenditures of $2,315,986. The difference is due to the omission of funds expended under a First Responder Equipment Grant, passed through the Missouri Department of Public Safety. The County also omitted the identifying number assigned by the pass-through entity for the grant agreement funded under this program. $2,145,888 of these funds were disbursed to subrecipients, however, these awards were not reported on the SEFA. The County reported $21,608 in expenditures under assistance listing number 97.042 - Emergency Management Performance Grants, however, the underlying accounting records support expenditures of $8,321. The County omitted the identifying numbers assigned by the pass-through entity for the each grant agreement funded under this program. Cause: The County has not implemented a proper system of internal control over SEFA preparation, such as a reconciliation to underlying accounting records or having a separate individual review the SEFA for clerical accuracy after it has been prepared. Reasons for discrepancies varied. Effect: The SEFA presented for the audit did not accurately reflect the County's actual expenditures of federal awards for the year ended December 31, 2024. Context: This is a repeat finding that was reported in the most current audit period as finding 2023-002. Recommendation: We recommend that the County implement internal controls to ensure that the SEFA completely and accurately states the expenditures of federal awards of the County each year, such as performing a reconciliation between the SEFA and underlying accounting records. Federal reimbursement grants should be reported on the SEFA based on reimbursable expenditures made during the year. Management's Response: The County Clerk and Treasurer will work with the accounts payable department to update and create spreadsheets and schedule a mid-year review of SEFA funds and grants. Implementation of spreadsheets is in progress and expected to be fully implemented by June 1, 2026.
Federal Grantor: U.S. Department of Treasury Pass-through Grantor: n/a Assistance Listing No.: 21.027 Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award Year: 2024 Compliance Requirement: Reporting Known Questioned Costs: n/a Criteria: Title 2 U.S. Code of Federal Regulations Part 200 requires recipients of Federal awards to comply with laws, regulations, and provisions of contract or grant agreements related to each of its Federal programs. Participants in the COVID-19 Coronavirus State and Local Fiscal Recovery Funds program were required to complete financial, performance, and compliance reporting as outlined in Part 2 of the SLFRF Compliance and Reporting Guide, issued by the U.S. Department of the Treasury. The County was required to appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. As a Tier 5 recipient, the County is required to submit annual reporting for each covered period by April 30. Condition: The County submitted the annual reporting, due April 30, 2024, on May 1, 2024. This submission is considered delinquent in accordance with reporting requirements set forth by the U.S. Department of the Treasury. FAQ 1.13 of the U.S. Department of the Treasury's Project and Expenditures Report User Guide states, "The data submitted by recipients will be used internally for oversight purposes and to fulfill Treasury's transparency and legal obligations. Late submissions undermine the efficiency and timeliness of these processes." Additionally, the annual reporting submitted contained reported errors in cumulative expenditures. Cause: Oversight. Effect: The Project and Expenditure Report due by April 30, 2024, which covered the period of April 1, 2023 - March 31, 2024, was submitted late with material errors in violation of the compliance obligations for recipients pursuant to the SLFRF statute. Context: This is a repeat finding that was reported in the most current audit period as finding 2023-003. Recommendation: We recommend that the County implement internal controls to ensure that the Project and Expenditure reports are reviewed and submitted timely and accurately in accordance with the terms and conditions set forth by the SLFRF statute. Management's Response: The federal reporting system still poses problems getting information uploaded. The County will actively seek out training videos and emailed information to help better understand the reporting system in order to have submission completed in a timely manner.
Federal Grantor: U.S. Department of Treasury Pass-through Grantor: n/a Assistance Listing No.: 21.027 Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award Year: 2024 Compliance Requirement: Subrecipient Monitoring Known Questioned Costs: n/a Criteria: Part 1 of the Compliance and Reporting Guidance, issued by the U.S. Department of the Treasury, states that "SLFRF recipients that are pass-through entities as described under 2 CFR 200.1 are required to manage and monitor their recipients to ensure compliance with requirements of the SLFRF award pursuant to 2 CFR 200.332 regarding requirements for pass-through entities." Additionally, it is stated that pass-through entities are required to clearly identify to the subrecipient any and all compliance requirements for use of SLFRF funds. Condition: The County requires potential recipients of SLFRF funds to complete an application, which clearly identifies any and all compliance requirements for the use of the SLFRF funds. It also advises potential recipients to retain documentation of all uses of the funds and produce those documents to the County upon request. The County awarded SLFRF funds to two subrecipients. For one of the two subrecipients, the County did not ask the subrecipient to produce any documentation of the use of the funds and, therefore, did not perform their duty as a pass-through entity to manage and monitor their recipients to ensure compliance. Additionally, the County did not properly ascertain that any subrecipients expected to be audited as required by the Uniform Guidance, under subpart F, met this requirement (2 CFR 200.331(f)). This verification performed as part of the required monitoring under 2 CFR 200.331(d)(2) is required to ensure that the subrecipient takes timely and appropriate action on deficiencies detected through audits. Cause: Oversight. Effect: The County, as a pass-through entity, is required to manage and monitor their recipients to ensure compliance with requirements of the SLFRF. By failing to manage and monitor one of their subrecipients, the County is in violation of their responsibility as a pass-through entity. Recommendation: We recommend that the County implement procedures for monitoring the spending of SLFRF funds by subrecipients during, and upon completion of their projects to ensure compliance. Management's Response: The County has created a filing system for recipients of SLFRF funds and a calendar set to send reminder notices to get receipts and other information from recipients. The reminders will be set in 3 month increments from the time funds are awarded to recipient. Implementation will begin January 1, 2026 with reminder notices set in calendar.