Audit 401913

Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform guidance) requires non-federal entities other than States to follow 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 sections 200.318 through 200.326. This includes using the small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(b). Condition, Cause, and Effect/Potential Effect: Internal controls at the County were not sufficient to ensure full and open competition on grant-funded contracts. Individuals involved in the procurement process incorrectly relied on NRS requirements instead of the County’s procurement policy and federal procurement guidelines. Questioned Costs: None noted. Context: A nonstatistical sample of the procurement transactions funded with the ARPA Coronavirus State and Local Recovery Funds revealed that the County did not conduct procurement transactions in a manner providing fair and open competition on two construction contracts. Recommendation: We recommend that the County provide additional training to grantoversight personnel and ensure controls are sufficiently enhanced to ensure procurement policies are followed on federal grant-funded purchases. Views of Responsible Officials and Planned Corrective Actions: We agree with this finding and will enhance control procedures as recommended. Repeat Finding from Prior Year: Yes; 2024-008.

Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.330, .331, and .332 requires that, as a pass-through entity, the County is responsible for identifying and reporting to the subrecipient the award information and applicable requirements to carrying out the award, as well as monitoring the activities of the subrecipient to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. Condition and Cause: Due to inadequate internal controls, the County did not provide complete and accurate subaward information to the subrecipient. Effect/Potential Effect: Subrecipients may not be aware of the grant reporting or compliance requirements for proper inclusion in their financial reports. Questioned Costs: None noted. Context: The County passed $101,794 through to the McDermitt GID and did not perform adequate procedures to ensure subrecipient compliance. This is not, however, deemed to be a questioned cost as no instances of material non-compliance were noted during our testing of the subrecipient’s grant activities. Recommendation: Internal control procedures should be enhanced to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials and Planned Corrective Actions: We agree with this finding and will enhance control procedures as recommended. Repeat Finding from Prior Year: Yes; 2024-007