CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER
UNIFORM GUIDANCE
City of Federal Way
January 1, 2022 through December 31, 2022
This schedule presents the corrective action the City is planning to take for findings included in
this report in accordance with Title 2 U.S. Code of Federal Regulations...
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER
UNIFORM GUIDANCE
City of Federal Way
January 1, 2022 through December 31, 2022
This schedule presents the corrective action the City is planning to take for findings included in
this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform
Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
(Uniform Guidance).
Finding ref number:
2022-001
Finding caption:
The City’s internal controls were inadequate for ensuring compliance with federal suspension and debarment requirements.
Name, address, and telephone of City contact person:
Steve Groom, Finance Director
33325 8th Avenue South, Federal Way, WA 98003-6325
(253) 835-2520
Corrective action the auditee plans to take in response to the finding:
The City concurs that maintaining strong internal controls is appropriate. Management is committed to taking immediate corrective action to ensure compliance with federal requirements.
Since the enactment of the SLFRF, city staff has made significant efforts to keep up with the multiple and evolving guidelines rules and FAQs issued by Treasury, and attended numerous trainings. Lack of guideline clarity produced information-sharing webinars hosted by reputable
state-wide and nation-wide associations such as AWC and GFOA. City staff, management and governing body exercised initial restraint in approving projects for spending of SLFRF funding in order to avoid inadvertently violating a rule issued subsequently. One example is that
exemption from Federal supplanting rules came out in later guidance and the City then proceeded relying on that explicit clarification.
Our position on this finding is that the rule in question seems to have been clarified after the City’s opportunity to comply had passed. The City remains dedicated to ensuring Federal funds are spent in compliance with all governing laws and regulations. The City’s immediate change being implemented is to eliminate recipients that cannot 1) register on SAM.gov, 2) contractually attest compliance or 3) provide self-attestation.
The City believes that adequate controls and procedures are in place and that internal training and communication are the appropriate corrective steps.
Anticipated date to complete the corrective action: Oct. 10, 2023