Finding No. 2022-002 Program: U.S. DEPARTMENT OF TREASURY CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS (CSLFRF) ? ASSISTANCE LISTING # 21.027; SLFRP4044 Auditor?s recommendation: We recommend the County formalize internal control policies and procedures, inclusive of a robust subrecipi...
Finding No. 2022-002 Program: U.S. DEPARTMENT OF TREASURY CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS (CSLFRF) ? ASSISTANCE LISTING # 21.027; SLFRP4044 Auditor?s recommendation: We recommend the County formalize internal control policies and procedures, inclusive of a robust subrecipient monitoring program., While the use of third-party consultants may be useful in the administration of a program of this size and nature, it is important to ensure the processes and documentation thereof, ensure the oversight and actions taken by the County are fully documented throughout the process. Moreover, the County should ensure that implemented policies and procedures ensure that all documentation is ultimately maintained by the County. The Uniform Guidance continues to highlight the importance and requirement for grantees to maintain internal control policies and procedures surrounding the compliance and administration of federal grants, focusing on clearly defining the key components (control environment, risk assessment, control activities, information and communication, monitoring). We recommend the County review and update current policies and procedures manuals to ensure all federal programs? internal control over compliance and central monitoring and reporting thereof is being met. Action Taken: The County implemented a plan associated with the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) to distribute funds to subrecipient communities located in Bristol County. The first expenditures associated with the program began in January 2022. Due to initial incomplete and change in guidance related to the CSLFRF, the County attempted to implement procedures associated with the program. Those procedures changed as the guidance changed. Now that the Final Rules of the CSLFRF have been determined, the County has developed a formalized internal control policy and procedures, including a robust subrecipient monitoring program. The procedures include control environment, risk assessment, control activities, and information and communication monitoring. As part of the procedure, the County insures that all documentation associated with subrecipient grants are maintained by the County. Attached hereto is the current subrecipient policies and procedures.