Audit 399031

2022-001 - Procurement Federal Program Information: CFDA - 21.027 - Coronavirus State and Local Fiscal Recovery Funds Criteria: The following CFR(s) apply to this finding: 2 CFR 200.317-327, 2 CFR section 200.314, 2 CFR 200 Appendix II . Condition: During audit procedures, it was identified that the County’s policies did not include procedures for micro and small purchases. The procurement history files did not include documentation of Debarment and Suspension search’s/certifications Cause: The County does not have the necessary internal controls over compliance. Effect: The County did not update its policies to include required micro and small purchase requirements. This increases the likelihood of using incorrect procurement methods. The lack of knowledge in procurement history file requirements to include Debarment and Suspension searches/certifications on contractors/vendors could result in contracting with ineligible contractors/vendors, increasing the likelihood of loss of federal funds. Identification of Questioned Costs: Payments for Identified project is $169,000, which appears to have been awarded without performing a Debarment and Suspension Search, or requiring the debarment and suspension certification, remedy/breach of contract clause, or termination clause. Context: Three of the Four Procurements for the County of Aroostook, Maine were tested. All three were missing the Debarment and Suspension search/certification. These were obtained later, after the fact. The procurement policy was missing the Micro and Small purchase threshold and requirements. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the County include Micro and Small purchase threshold and methods in their Procurement Policy and implement internal control processes and procedures over Debarment and Suspension to ensure compliance with federal requirements. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the County of Aroostook, Maine.

2022-002 - Subrecipient Monitoring Federal Program Information: CFDA - 21.027 - Coronavirus State and Local Fiscal Recovery Funds Criteria: The following CFR(s) apply to this finding: 2 CFR 200.214 is the requirement of a Debarment and Suspension Search on subrecipients and 2 CFR 200.332(a) which includes what must be included in the subaward agreements and monitoring requirements. Condition: During audit procedures, it was identified that the County’s uses the ARPA program statement for the subrecipient monitoring policy and procedure and does not have a separate subrecipient policy and procedure, which has not been an effective method. The subawards did not include the required Federal Award Identification number, Assistance Listing Number, no mention of the approved indirect cost rate. The subrecipient monitoring documentation did not provide any indication of review of the financial reports, whether or not there were any deficiencies, corrective actions if needed, management letter comments/finding if needed, and no verification as to whether the subrecipient would need a single audit. Cause: The County does not have the necessary internal controls over subrecipient monitoring compliance requirements. The lack of experience and knowledge of the program may be a key factor in the lack of internal controls. Effect: As a pass-through entity the County is not providing the necessary federal identification information, nor is it properly monitoring the subrecipients for the required compliance requirements of the program. This increases the likelihood of ineligible subrecipients that are on the Debarment and Suspension list to receive federal funds and the likelihood of misuse of federal funds and noncompliance with the requirements of the program. Increasing the likelihood of loss of funding and inability to receive future funding. Identification of Questioned Costs: Identified Subrecipient award Payments totaled $264,943.38. For which no Debarment or Suspension search was done, none of the monitoring requirements appeared to be performed on any of the subrecipients tested and one subrecipient did not go thru the application process for proper vetting. Context: All Five of the Seven Subrecipients receiving funding during FY22 were reviewed. None of the Five were searched in SAM.gov for Debarment and Suspension. 1 was approved without applying for the funds, none were properly monitored for compliance requirements. All Five subawards were missing the Federal Award Identification Number, ALN, indirect cost rate. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the County write their own policy and procedure for subrecipient monitoring and implement a process to include a debarment and suspension search for all subrecipients on sam.gov to ensure compliance with federal requirements. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the County of Aroostook, Maine.