Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Various Pass-Through Agency: State of Connecticut Department of Children & Families, State of Connecticut Judicial Branch, City of Norwalk, City of New Haven Pass-Through Numbers: Various Award Period: Various Type of Finding: • Significant Deficiency in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The procurement policy and conflict of interest policy of the Organization do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: No costs have been questioned. Context: Although the Organization did not have a policy in place that is fully in conformity with the Federal Uniform Guidance criteria, the Organization did follow the Federal procedures as it relates to the contracts under the procurements applicable to the Organization's major program. Cause: Management was unaware of the restrictive requirements of the procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Finding does not represent a repeat finding. Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management concurs with the finding. Refer to the separate corrective action plan.
Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Various Pass-Through Agency: State of Connecticut Department of Children & Families, State of Connecticut Judicial Branch, City of Norwalk, City of New Haven Pass-Through Numbers: Various Award Period: Various Type of Finding: • Significant Deficiency in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The procurement policy and conflict of interest policy of the Organization do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: No costs have been questioned. Context: Although the Organization did not have a policy in place that is fully in conformity with the Federal Uniform Guidance criteria, the Organization did follow the Federal procedures as it relates to the contracts under the procurements applicable to the Organization's major program. Cause: Management was unaware of the restrictive requirements of the procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Finding does not represent a repeat finding. Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management concurs with the finding. Refer to the separate corrective action plan.
Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Various Pass-Through Agency: State of Connecticut Department of Children & Families, State of Connecticut Judicial Branch, City of Norwalk, City of New Haven Pass-Through Numbers: Various Award Period: Various Type of Finding: • Significant Deficiency in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The procurement policy and conflict of interest policy of the Organization do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: No costs have been questioned. Context: Although the Organization did not have a policy in place that is fully in conformity with the Federal Uniform Guidance criteria, the Organization did follow the Federal procedures as it relates to the contracts under the procurements applicable to the Organization's major program. Cause: Management was unaware of the restrictive requirements of the procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Finding does not represent a repeat finding. Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management concurs with the finding. Refer to the separate corrective action plan.
Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Various Pass-Through Agency: State of Connecticut Department of Children & Families, State of Connecticut Judicial Branch, City of Norwalk, City of New Haven Pass-Through Numbers: Various Award Period: Various Type of Finding: • Significant Deficiency in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The procurement policy and conflict of interest policy of the Organization do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: No costs have been questioned. Context: Although the Organization did not have a policy in place that is fully in conformity with the Federal Uniform Guidance criteria, the Organization did follow the Federal procedures as it relates to the contracts under the procurements applicable to the Organization's major program. Cause: Management was unaware of the restrictive requirements of the procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Finding does not represent a repeat finding. Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management concurs with the finding. Refer to the separate corrective action plan.
Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Various Pass-Through Agency: State of Connecticut Department of Children & Families, State of Connecticut Judicial Branch, City of Norwalk, City of New Haven Pass-Through Numbers: Various Award Period: Various Type of Finding: • Significant Deficiency in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The procurement policy and conflict of interest policy of the Organization do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: No costs have been questioned. Context: Although the Organization did not have a policy in place that is fully in conformity with the Federal Uniform Guidance criteria, the Organization did follow the Federal procedures as it relates to the contracts under the procurements applicable to the Organization's major program. Cause: Management was unaware of the restrictive requirements of the procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Finding does not represent a repeat finding. Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management concurs with the finding. Refer to the separate corrective action plan.
Federal Agency: Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Various Pass-Through Agency: State of Connecticut Department of Children & Families, State of Connecticut Judicial Branch, City of Norwalk, City of New Haven Pass-Through Numbers: Various Award Period: Various Type of Finding: • Significant Deficiency in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: The Organization must comply with procurement standards set out at 2 CFR sections 200.318 through 200.326 within Uniform Guidance. Condition: The procurement policy and conflict of interest policy of the Organization do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: No costs have been questioned. Context: Although the Organization did not have a policy in place that is fully in conformity with the Federal Uniform Guidance criteria, the Organization did follow the Federal procedures as it relates to the contracts under the procurements applicable to the Organization's major program. Cause: Management was unaware of the restrictive requirements of the procurement standards. Effect: With the absence of a compliant policy, the Organization is at risk for noncompliance as it relates to federal procurement. Repeat Finding: Finding does not represent a repeat finding. Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials: Management concurs with the finding. Refer to the separate corrective action plan.
2023-003 Uniform Guidance Written Policies and Procedures Significant Deficiency in Internal Control over Compliance Criteria Uniform Guidance 2 CFR Part 180 requires written policies and procedures related to Internal controls be written regarding SAMS. gov contractor verification of debarment and suspension. In addition, 2 CFR Part 200.326 Contract Provisions that pay over $2,000 in labor wages are required to be in compliant with Davis Bacon Labor Laws. This requirement contains written achnowledgement of certified wage rate payrolls weekly and contractual language of the wage rate certification of payroll in the contract between the contractor and the Joint Powers Board. Cause Tongue River Valley Joint Powers Board do not have written updated policies implementing Uniform Guidance contractual and internal control procedures. They operate under the WY Statues - which covers entities within Wyoming jurisdiction, however the Joint Powers Board also has Federal requirements due to the Federal USDA loan. Condition Without lack of written policies, the Joint Powers Board could enter transactions with debarred or suspended vendors, and not pay adequate Federal wages to labors. Effect The Joint Powers Board must use funds efficiently and effectively and in accordance with Federal OMB Uniform Guidance to prevent mismanagement of projects funded by Federal awards. Questioned Costs Less than $25,000 Recommendation We recommend that the Joint Power Board update their written internal control policies to contain all Uniform Guidance regulations, relating to Sams. gov debarment and suspension and Davis Bacon Wage Requirements. It is recommended that these be policies and internal controls be reviewed and aligned with the Federal Award contractual agreeements on a routine basis. View of Responsible Officials and Planned Corrective Actions Please see the last page of this report for the written response from the Board.
Program: Education Stabilization Fund COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief (84.425U) Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141-3144, 3146, and 3147). Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor of subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215 Appendix A, Contract Provisions; 2 CFR Part 176 Subpart C; and 2 CFR section 200.326). Context and Condition: We reviewed the District’s construction contract that was financed by the Education Stabilization Fund during the year ended June 30, 2023 and performed testing over internal controls and compliance as related to the Wage Rate Requirements as outlined in the criteria above. Cause: The District did not have processes or controls established to ensure certified payrolls for each week in which contract work was performed were obtained from the contractor or subcontractor for construction contracts financed by the Education Stabilization Fund until after the construction contract was completed. Effect: A potential failure to pay laborers and mechanics employed by contractors or subcontractors prevailing wage rates as required by the Wage Rate Requirements exists. Questioned Costs: No costs were questionable. Repeat Finding: No Statistically valid: Yes Recommendation: We recommend management of the District review processes related to construction projects subject to the Wage Rate Requirements and establish appropriate internal controls to ensure all wage rate requirements are met. Views of responsible officials: Management of the District has reviewed the processes and internal controls related to construction contracts and have implemented changes to ensure that the Wage Rate Requirements are adhered to when applicable.
Material noncompliance and material weakness in internal control over compliance with procurement and suspension and debarment procedures meeting the requirements of 2 CFR Part 200. Federal Agency: United States Department Treasury Program Titles: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Entity: King County Regional Homeless Authority Award Numbers: DA-202303-01737 Award Periods: March 15, 2023 through August 31, 2023 Criteria Internal controls requirements contained in Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) , Subpart D ‐ Post Federal Award Requirements, Section 200.318 through 200.326 Internal Controls, require that a non‐Federal entity use 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 requirement identified in 2 CFR Part 200. Condition/Context The Organization has a procurement policy, which includes procedures to include documenting the history of the procurement, including justification of the procurement method utilized. For 3 of 3 procurements selected for testing over the micro-purchase threshold the Organization could not produce contemporaneous documentation supporting the history of the procurement including justification for utilization of the noncompetitive procurement method of procurement and performance of suspension and debarment search. The Organization determined at the time of procurement that due to a state of public emergency the noncompetitive procurement methodology was in compliance with the Uniform Guidance. Further, subsequent to audit testing the Organization received approval from the pass-through funder that a noncompetitive procurement methodology was authorized. Cause The Organization did not have internal controls in place to ensure that the Organization’s procurement policy was followed by retaining documentation of management consideration and conclusion when procuring goods and services. Effect The Organization entered into agreements to procure goods and services for which no documentation was retained to support the history of the procurement. Questioned Costs $0 Repeat Finding Not a repeat finding. Recommendation We recommend the Organization implement internal controls to ensure that documentation is retained to support procurements in accordance with its procurement policy. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.
Federal Agency: U.S. Department of Education Federal Program Name: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the State and Local Fiscal Recovery Funds program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: All 5 of the procurements which were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District review its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the State and Local Fiscal Recovery Funds program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: All 5 of the procurements which were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District review its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the State and Local Fiscal Recovery Funds program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: All 5 of the procurements which were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District review its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: Unknown Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the State and Local Fiscal Recovery Funds program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: All 5 of the procurements which were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This is a repeat finding. Recommendation: We recommend the District review its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: For 2 out of the 3 procurements that were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: For 2 out of the 3 procurements that were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: For 2 out of the 3 procurements that were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, 2023 Pass-Through Agency: Minnesota Department of Education Pass-Through Numbers: H027A210087, H027X210087, H173A210086, H173X210086 Award Period: July 1, 2022 – September 30, 2023 Type of Finding: Material Weakness in Internal Control Over Compliance and Compliance Finding (Modified Opinion) Criteria or Specific Requirement: Non-federal entities other than states must follow the procurement standards set out at c CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District’s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Context: For 2 out of the 3 procurements that were tested, we noted that the District did not retain documentation detailing the procurement process or what quotes were obtained. Questioned Costs: None Cause: Time pressure led to this requirement not being met. Effect: The District was not in compliance with the documentation requirements for procurement transactions as detailed in the Uniform Guidance. Repeat Finding: This a repeat finding. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004 - Procurement, Suspension & Debarment Federal Program Information: ALN - 10.760 - Water and Waste Disposal Systems for Rural Communities Criteria: The following CFR(s) apply to this finding: 2 CFR 200.317-200.326. Condition: During audit procedures, it was identified that the Town did not have a procurement policy in place. Cause: The Town needs to adopt a procurement policy to comply with Uniform Guidance. Effect: Procurements might not conform to applicable Federal laws. Identification of Questioned Costs: None identified. Context: The entire population. Repeat Finding: This is a repeat finding of 2022-004. Recommendation: It is recommended that the Town adopt a procurement policy that follows the Uniform Guidance and that the Town implement internal control processes and procedures to ensure that the adopted policy is followed. Views of Responsible Officials and Corrective Action Plan: Client agrees with finding and a version of their response can be found in the Corrective Action Plan. Please see the Corrective Action Plan issued by the Town of Livermore Falls.
2023-007- Procurement, Suspension & Debarment Federal Program Information: ALN - 66.458 - Clean Water State Revolving Funds Criteria: The following CFR(s) apply to this finding: 2 CFR 200.317 - 200.326. Condition: During audit procedures, it was identified that the Town did not have a procurement policy in place. Cause: The Town needs to adopt a procurement policy to comply with Uniform Guidance. Effect: Procurements might not conform to applicable Federal laws. Identification of Questioned Costs: None identified. Context: The entire population Repeat Finding: This is not a repeat finding Recommendation: It is recommended that the Town adopt a procurement policy that follows the Uniform Guidance and that the Town implements internal control processes and procedures to ensure that the adopted policy is followed. Views of Responsible Officials and Corrective Action Plan: Client agrees with finding and a version of their response can be found in the Corrective Action Plan. Please see the Corrective Action Plan issued by the Town of Livermore Falls.
2023-007- Procurement, Suspension & Debarment Federal Program Information: ALN - 66.458 - Clean Water State Revolving Funds Criteria: The following CFR(s) apply to this finding: 2 CFR 200.317 - 200.326. Condition: During audit procedures, it was identified that the Town did not have a procurement policy in place. Cause: The Town needs to adopt a procurement policy to comply with Uniform Guidance. Effect: Procurements might not conform to applicable Federal laws. Identification of Questioned Costs: None identified. Context: The entire population Repeat Finding: This is not a repeat finding Recommendation: It is recommended that the Town adopt a procurement policy that follows the Uniform Guidance and that the Town implements internal control processes and procedures to ensure that the adopted policy is followed. Views of Responsible Officials and Corrective Action Plan: Client agrees with finding and a version of their response can be found in the Corrective Action Plan. Please see the Corrective Action Plan issued by the Town of Livermore Falls.
2023-007- Procurement, Suspension & Debarment Federal Program Information: ALN - 66.458 - Clean Water State Revolving Funds Criteria: The following CFR(s) apply to this finding: 2 CFR 200.317 - 200.326. Condition: During audit procedures, it was identified that the Town did not have a procurement policy in place. Cause: The Town needs to adopt a procurement policy to comply with Uniform Guidance. Effect: Procurements might not conform to applicable Federal laws. Identification of Questioned Costs: None identified. Context: The entire population Repeat Finding: This is not a repeat finding Recommendation: It is recommended that the Town adopt a procurement policy that follows the Uniform Guidance and that the Town implements internal control processes and procedures to ensure that the adopted policy is followed. Views of Responsible Officials and Corrective Action Plan: Client agrees with finding and a version of their response can be found in the Corrective Action Plan. Please see the Corrective Action Plan issued by the Town of Livermore Falls.
2023-007- Procurement, Suspension & Debarment Federal Program Information: ALN - 66.458 - Clean Water State Revolving Funds Criteria: The following CFR(s) apply to this finding: 2 CFR 200.317 - 200.326. Condition: During audit procedures, it was identified that the Town did not have a procurement policy in place. Cause: The Town needs to adopt a procurement policy to comply with Uniform Guidance. Effect: Procurements might not conform to applicable Federal laws. Identification of Questioned Costs: None identified. Context: The entire population Repeat Finding: This is not a repeat finding Recommendation: It is recommended that the Town adopt a procurement policy that follows the Uniform Guidance and that the Town implements internal control processes and procedures to ensure that the adopted policy is followed. Views of Responsible Officials and Corrective Action Plan: Client agrees with finding and a version of their response can be found in the Corrective Action Plan. Please see the Corrective Action Plan issued by the Town of Livermore Falls.
Significant Deficiency – Item 2023-002 – Insufficient Required Substantiating Documentation for Major Programs Condition: Several expenditures and reports were selected for substantive, controls, and compliance testing from the financial records for the major programs. In several cases, the source documents supporting the federal expenditures reported were not accurate, missing and/or properly described. For expenditures allocated between award programs benefitted there was no written allocation methodology used including how costs were calculated and charged to each program. Federal regulations required that all federal expenditures must be supported by adequate source documents and accounting and cost records. Documentation must stipulate the nature of the expenditure (exactly what the funds were spent on), the purpose of the cost, the applicable federal program name, the cost for each product and service that agrees with the financial records and report to the federal funding source. In addition, PCCD provides to all related providers their “Financial and Administrative Guide for Grants” that clearly stipulates the nature of all substantiating documentation and reporting for all federal expenditures. Several expenditures tested included evidence of accounting system-generated approvals. In several cases, the person purchasing products and services also approved the expenditure. Along with that approval, there was another approval by the CFO, but the sign off showed that name as “Inactive”. For one of the PCCD contracts with subrecipients, periodically the Organization provides advances. However there is no accounting for use of the advances, and unused balances at period end are not reported on the financial statements. There are very explicit federal guidelines for time and effort accounting and reporting. Testing revealed discrepancies between individual’s time records, the payroll and check registers, posting to the general ledger, and the periodic reports to funders. In certain cases, the HR Supervisor approved hours included in timesheets that were not accurate. The time sheet hours exceeded the amount subsequently paid to the individual. Reconciliation of differences was a difficult process and the end result was a remaining difference not explained. Some timesheets for the program manager showed every posting was labelled with the wrong federal program name. Criteria: All expenditures charged to federal programs must be clearly and completely supported by required documentation that agrees with amounts in the Organization’s general ledger and periodic reports to the federal grantor. Cause: The Organization does not maintain written policies and procedures for procurement and reporting related to all financial transactions under federally-funded programs, including allowable costs and other federal compliance requirements. Procurement policies must adhere to the “Uniform Administrative Requirements, Cost Principles and Audit Requirements” for federal awards in 2CFR200.318 through 200.326. There is no formal Accounting Manual that is periodically revised when new grants are awarded or when the personnel pool changes. The written document must include a code of conduct for the Organization. When a new federal award is granted to the Organization with specific financial and administrative requirements, the manual should be revised to incorporate those requirements. The Organization has also experienced turnover of key personnel in the Finance Department. Effect: Several expenditures selected for testing were not properly documented in accordance with federal regulations. In several cases, the only supporting documentation was adjusting journal entries posted to the general ledger. In one case, an amount of $5,200 was posted to the general ledger under “Other Supportive Services”, but the Organization could not provide a copy of the adjusting entry nor any related documentation or explanation. In July 2022, costs totaling $5,500 were recorded that were related to expenses incurred in June 2022. The result of these deficiencies may be misstatement of costs that are periodically reported for reimbursement by the funder. Questioned Costs: The total estimated questioned costs for both major programs was $19,451. Certain tested expenditures included significant purchases of gas and gift cards and rail passes. For example, various amounts spent on individual purchases included $11,587, $16,773, and $47,801. These amounts are in addition to the questioned costs above. There were invoices for cards and passes that indicated they were sent to the Program Manager’s home address under his name and a related business name. There are no written control procedures for these purchases and no inventory is maintained of the supply on hand at any given time. Also, there no records supporting how the cards were distributed. On the related invoices for these purchases, there is insufficient documentation including no program names or purpose. Recommendation: All employees in the Finance Department and associated with any federal program must be adequately trained in overall federal regulations and guidance as well as other requirements associated with each federal award. All such employees must read the grant-related policies and procedures manual (to be developed) and accounting manual with the code of conduct. In addition, each month, finance should compare grant expenditures posted to the general ledger to the monthly grant reports and budgets. Management’s Response: Impact has experienced staff turnover which resulted in process challenges. Nevertheless, Impact will take this recommendation and implement revised procedures to ensure that the Finance Department and other pertinent Impact resources receive federal regulations and guidance training, incorporate available systems and technology capabilities available from the technology service providers, and adopt best practices. Finance will schedule regular grant reviews, inclusive of program expenditures. These improvements will be in place by March 31, 2025.
Significant Deficiency – Item 2023-002 – Insufficient Required Substantiating Documentation for Major Programs Condition: Several expenditures and reports were selected for substantive, controls, and compliance testing from the financial records for the major programs. In several cases, the source documents supporting the federal expenditures reported were not accurate, missing and/or properly described. For expenditures allocated between award programs benefitted there was no written allocation methodology used including how costs were calculated and charged to each program. Federal regulations required that all federal expenditures must be supported by adequate source documents and accounting and cost records. Documentation must stipulate the nature of the expenditure (exactly what the funds were spent on), the purpose of the cost, the applicable federal program name, the cost for each product and service that agrees with the financial records and report to the federal funding source. In addition, PCCD provides to all related providers their “Financial and Administrative Guide for Grants” that clearly stipulates the nature of all substantiating documentation and reporting for all federal expenditures. Several expenditures tested included evidence of accounting system-generated approvals. In several cases, the person purchasing products and services also approved the expenditure. Along with that approval, there was another approval by the CFO, but the sign off showed that name as “Inactive”. For one of the PCCD contracts with subrecipients, periodically the Organization provides advances. However there is no accounting for use of the advances, and unused balances at period end are not reported on the financial statements. There are very explicit federal guidelines for time and effort accounting and reporting. Testing revealed discrepancies between individual’s time records, the payroll and check registers, posting to the general ledger, and the periodic reports to funders. In certain cases, the HR Supervisor approved hours included in timesheets that were not accurate. The time sheet hours exceeded the amount subsequently paid to the individual. Reconciliation of differences was a difficult process and the end result was a remaining difference not explained. Some timesheets for the program manager showed every posting was labelled with the wrong federal program name. Criteria: All expenditures charged to federal programs must be clearly and completely supported by required documentation that agrees with amounts in the Organization’s general ledger and periodic reports to the federal grantor. Cause: The Organization does not maintain written policies and procedures for procurement and reporting related to all financial transactions under federally-funded programs, including allowable costs and other federal compliance requirements. Procurement policies must adhere to the “Uniform Administrative Requirements, Cost Principles and Audit Requirements” for federal awards in 2CFR200.318 through 200.326. There is no formal Accounting Manual that is periodically revised when new grants are awarded or when the personnel pool changes. The written document must include a code of conduct for the Organization. When a new federal award is granted to the Organization with specific financial and administrative requirements, the manual should be revised to incorporate those requirements. The Organization has also experienced turnover of key personnel in the Finance Department. Effect: Several expenditures selected for testing were not properly documented in accordance with federal regulations. In several cases, the only supporting documentation was adjusting journal entries posted to the general ledger. In one case, an amount of $5,200 was posted to the general ledger under “Other Supportive Services”, but the Organization could not provide a copy of the adjusting entry nor any related documentation or explanation. In July 2022, costs totaling $5,500 were recorded that were related to expenses incurred in June 2022. The result of these deficiencies may be misstatement of costs that are periodically reported for reimbursement by the funder. Questioned Costs: The total estimated questioned costs for both major programs was $19,451. Certain tested expenditures included significant purchases of gas and gift cards and rail passes. For example, various amounts spent on individual purchases included $11,587, $16,773, and $47,801. These amounts are in addition to the questioned costs above. There were invoices for cards and passes that indicated they were sent to the Program Manager’s home address under his name and a related business name. There are no written control procedures for these purchases and no inventory is maintained of the supply on hand at any given time. Also, there no records supporting how the cards were distributed. On the related invoices for these purchases, there is insufficient documentation including no program names or purpose. Recommendation: All employees in the Finance Department and associated with any federal program must be adequately trained in overall federal regulations and guidance as well as other requirements associated with each federal award. All such employees must read the grant-related policies and procedures manual (to be developed) and accounting manual with the code of conduct. In addition, each month, finance should compare grant expenditures posted to the general ledger to the monthly grant reports and budgets. Management’s Response: Impact has experienced staff turnover which resulted in process challenges. Nevertheless, Impact will take this recommendation and implement revised procedures to ensure that the Finance Department and other pertinent Impact resources receive federal regulations and guidance training, incorporate available systems and technology capabilities available from the technology service providers, and adopt best practices. Finance will schedule regular grant reviews, inclusive of program expenditures. These improvements will be in place by March 31, 2025.
Significant Deficiency – Item 2023-002 – Insufficient Required Substantiating Documentation for Major Programs Condition: Several expenditures and reports were selected for substantive, controls, and compliance testing from the financial records for the major programs. In several cases, the source documents supporting the federal expenditures reported were not accurate, missing and/or properly described. For expenditures allocated between award programs benefitted there was no written allocation methodology used including how costs were calculated and charged to each program. Federal regulations required that all federal expenditures must be supported by adequate source documents and accounting and cost records. Documentation must stipulate the nature of the expenditure (exactly what the funds were spent on), the purpose of the cost, the applicable federal program name, the cost for each product and service that agrees with the financial records and report to the federal funding source. In addition, PCCD provides to all related providers their “Financial and Administrative Guide for Grants” that clearly stipulates the nature of all substantiating documentation and reporting for all federal expenditures. Several expenditures tested included evidence of accounting system-generated approvals. In several cases, the person purchasing products and services also approved the expenditure. Along with that approval, there was another approval by the CFO, but the sign off showed that name as “Inactive”. For one of the PCCD contracts with subrecipients, periodically the Organization provides advances. However there is no accounting for use of the advances, and unused balances at period end are not reported on the financial statements. There are very explicit federal guidelines for time and effort accounting and reporting. Testing revealed discrepancies between individual’s time records, the payroll and check registers, posting to the general ledger, and the periodic reports to funders. In certain cases, the HR Supervisor approved hours included in timesheets that were not accurate. The time sheet hours exceeded the amount subsequently paid to the individual. Reconciliation of differences was a difficult process and the end result was a remaining difference not explained. Some timesheets for the program manager showed every posting was labelled with the wrong federal program name. Criteria: All expenditures charged to federal programs must be clearly and completely supported by required documentation that agrees with amounts in the Organization’s general ledger and periodic reports to the federal grantor. Cause: The Organization does not maintain written policies and procedures for procurement and reporting related to all financial transactions under federally-funded programs, including allowable costs and other federal compliance requirements. Procurement policies must adhere to the “Uniform Administrative Requirements, Cost Principles and Audit Requirements” for federal awards in 2CFR200.318 through 200.326. There is no formal Accounting Manual that is periodically revised when new grants are awarded or when the personnel pool changes. The written document must include a code of conduct for the Organization. When a new federal award is granted to the Organization with specific financial and administrative requirements, the manual should be revised to incorporate those requirements. The Organization has also experienced turnover of key personnel in the Finance Department. Effect: Several expenditures selected for testing were not properly documented in accordance with federal regulations. In several cases, the only supporting documentation was adjusting journal entries posted to the general ledger. In one case, an amount of $5,200 was posted to the general ledger under “Other Supportive Services”, but the Organization could not provide a copy of the adjusting entry nor any related documentation or explanation. In July 2022, costs totaling $5,500 were recorded that were related to expenses incurred in June 2022. The result of these deficiencies may be misstatement of costs that are periodically reported for reimbursement by the funder. Questioned Costs: The total estimated questioned costs for both major programs was $19,451. Certain tested expenditures included significant purchases of gas and gift cards and rail passes. For example, various amounts spent on individual purchases included $11,587, $16,773, and $47,801. These amounts are in addition to the questioned costs above. There were invoices for cards and passes that indicated they were sent to the Program Manager’s home address under his name and a related business name. There are no written control procedures for these purchases and no inventory is maintained of the supply on hand at any given time. Also, there no records supporting how the cards were distributed. On the related invoices for these purchases, there is insufficient documentation including no program names or purpose. Recommendation: All employees in the Finance Department and associated with any federal program must be adequately trained in overall federal regulations and guidance as well as other requirements associated with each federal award. All such employees must read the grant-related policies and procedures manual (to be developed) and accounting manual with the code of conduct. In addition, each month, finance should compare grant expenditures posted to the general ledger to the monthly grant reports and budgets. Management’s Response: Impact has experienced staff turnover which resulted in process challenges. Nevertheless, Impact will take this recommendation and implement revised procedures to ensure that the Finance Department and other pertinent Impact resources receive federal regulations and guidance training, incorporate available systems and technology capabilities available from the technology service providers, and adopt best practices. Finance will schedule regular grant reviews, inclusive of program expenditures. These improvements will be in place by March 31, 2025.
Significant Deficiency – Item 2023-002 – Insufficient Required Substantiating Documentation for Major Programs Condition: Several expenditures and reports were selected for substantive, controls, and compliance testing from the financial records for the major programs. In several cases, the source documents supporting the federal expenditures reported were not accurate, missing and/or properly described. For expenditures allocated between award programs benefitted there was no written allocation methodology used including how costs were calculated and charged to each program. Federal regulations required that all federal expenditures must be supported by adequate source documents and accounting and cost records. Documentation must stipulate the nature of the expenditure (exactly what the funds were spent on), the purpose of the cost, the applicable federal program name, the cost for each product and service that agrees with the financial records and report to the federal funding source. In addition, PCCD provides to all related providers their “Financial and Administrative Guide for Grants” that clearly stipulates the nature of all substantiating documentation and reporting for all federal expenditures. Several expenditures tested included evidence of accounting system-generated approvals. In several cases, the person purchasing products and services also approved the expenditure. Along with that approval, there was another approval by the CFO, but the sign off showed that name as “Inactive”. For one of the PCCD contracts with subrecipients, periodically the Organization provides advances. However there is no accounting for use of the advances, and unused balances at period end are not reported on the financial statements. There are very explicit federal guidelines for time and effort accounting and reporting. Testing revealed discrepancies between individual’s time records, the payroll and check registers, posting to the general ledger, and the periodic reports to funders. In certain cases, the HR Supervisor approved hours included in timesheets that were not accurate. The time sheet hours exceeded the amount subsequently paid to the individual. Reconciliation of differences was a difficult process and the end result was a remaining difference not explained. Some timesheets for the program manager showed every posting was labelled with the wrong federal program name. Criteria: All expenditures charged to federal programs must be clearly and completely supported by required documentation that agrees with amounts in the Organization’s general ledger and periodic reports to the federal grantor. Cause: The Organization does not maintain written policies and procedures for procurement and reporting related to all financial transactions under federally-funded programs, including allowable costs and other federal compliance requirements. Procurement policies must adhere to the “Uniform Administrative Requirements, Cost Principles and Audit Requirements” for federal awards in 2CFR200.318 through 200.326. There is no formal Accounting Manual that is periodically revised when new grants are awarded or when the personnel pool changes. The written document must include a code of conduct for the Organization. When a new federal award is granted to the Organization with specific financial and administrative requirements, the manual should be revised to incorporate those requirements. The Organization has also experienced turnover of key personnel in the Finance Department. Effect: Several expenditures selected for testing were not properly documented in accordance with federal regulations. In several cases, the only supporting documentation was adjusting journal entries posted to the general ledger. In one case, an amount of $5,200 was posted to the general ledger under “Other Supportive Services”, but the Organization could not provide a copy of the adjusting entry nor any related documentation or explanation. In July 2022, costs totaling $5,500 were recorded that were related to expenses incurred in June 2022. The result of these deficiencies may be misstatement of costs that are periodically reported for reimbursement by the funder. Questioned Costs: The total estimated questioned costs for both major programs was $19,451. Certain tested expenditures included significant purchases of gas and gift cards and rail passes. For example, various amounts spent on individual purchases included $11,587, $16,773, and $47,801. These amounts are in addition to the questioned costs above. There were invoices for cards and passes that indicated they were sent to the Program Manager’s home address under his name and a related business name. There are no written control procedures for these purchases and no inventory is maintained of the supply on hand at any given time. Also, there no records supporting how the cards were distributed. On the related invoices for these purchases, there is insufficient documentation including no program names or purpose. Recommendation: All employees in the Finance Department and associated with any federal program must be adequately trained in overall federal regulations and guidance as well as other requirements associated with each federal award. All such employees must read the grant-related policies and procedures manual (to be developed) and accounting manual with the code of conduct. In addition, each month, finance should compare grant expenditures posted to the general ledger to the monthly grant reports and budgets. Management’s Response: Impact has experienced staff turnover which resulted in process challenges. Nevertheless, Impact will take this recommendation and implement revised procedures to ensure that the Finance Department and other pertinent Impact resources receive federal regulations and guidance training, incorporate available systems and technology capabilities available from the technology service providers, and adopt best practices. Finance will schedule regular grant reviews, inclusive of program expenditures. These improvements will be in place by March 31, 2025.
Condition: The Organization’s written policies and procedures related to financial management and procurement do not meet the requirements of 2 CFR 200, Subpart D and Subpart E. Criteria: According to 2 CFR Section 200.302.b and 2 CFR Section 200.305 of the Uniform Guidance, the Organization is required to have a written financial management policy. Additionally, according to 2 CFR Section 200.317 – 200.326, the Organization is required to have a written procurement policy. Cause: The Organization was unaware of requirements regarding policies and procedures outlined in the Uniform Guidance. Effect: Written policies necessary for non-Federal entities receiving federal funds were not in place. Repeat Finding: No Questioned Costs: None reported Recommendation: We recommend that the Organization update their written policies and procedures that meet the requirements of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Views of Responsible Officials and Planned Corrective Action: We concur with the auditor’s finding and will update the Organization’s written policies and procedures for the Uniform Guidance requirements.
Condition: The Organization’s written policies and procedures related to financial management and procurement do not meet the requirements of 2 CFR 200, Subpart D and Subpart E. Criteria: According to 2 CFR Section 200.302.b and 2 CFR Section 200.305 of the Uniform Guidance, the Organization is required to have a written financial management policy. Additionally, according to 2 CFR Section 200.317 – 200.326, the Organization is required to have a written procurement policy. Cause: The Organization was unaware of requirements regarding policies and procedures outlined in the Uniform Guidance. Effect: Written policies necessary for non-Federal entities receiving federal funds were not in place. Repeat Finding: No Questioned Costs: None reported Recommendation: We recommend that the Organization update their written policies and procedures that meet the requirements of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Views of Responsible Officials and Planned Corrective Action: We concur with the auditor’s finding and will update the Organization’s written policies and procedures for the Uniform Guidance requirements.
Condition: The Organization’s written policies and procedures related to financial management and procurement do not meet the requirements of 2 CFR 200, Subpart D and Subpart E. Criteria: According to 2 CFR Section 200.302.b and 2 CFR Section 200.305 of the Uniform Guidance, the Organization is required to have a written financial management policy. Additionally, according to 2 CFR Section 200.317 – 200.326, the Organization is required to have a written procurement policy. Cause: The Organization was unaware of requirements regarding policies and procedures outlined in the Uniform Guidance. Effect: Written policies necessary for non-Federal entities receiving federal funds were not in place. Repeat Finding: No Questioned Costs: None reported Recommendation: We recommend that the Organization update their written policies and procedures that meet the requirements of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Views of Responsible Officials and Planned Corrective Action: We concur with the auditor’s finding and will update the Organization’s written policies and procedures for the Uniform Guidance requirements.
Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555 Federal Award Identification Number and Year: 12060-SDE64370-20560 Pass-Through Agency: State Department of Education Pass-Through Number(s): N/A Award Period: 7/1/2022 - 6/30/2023 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters (Noncompliance) Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement standards. Condition: The Board of Education’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None noted. Context: Although the Board of Education did not have a policy in place in conformity with the federal uniform guidance criteria, the Board of Education did follow their purchasing policies. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: With the absence of a compliant policy, the Board of Education is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No Recommendation: We recommend that the Board of Education review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and is in process of developing a formal policy.
Federal Agency: Department of the Treasury, Department of Agriculture and Department of Transportation Federal Program Name: American Rescue Plan Act, Child Nutrition Cluster, and Highway Planning and Construction Assistance Listing Number: 21.027,10.553/10.555, and 20.205 Federal Award Identification Number and Year: 12060-OPM20600-29669, 12060-SDE64370-20560 and 12062-DOT57191-22108 Pass-Through Agency: Office of Policy and Management and State Department of Education and State Department of Transportation Pass-Through Number(s): N/A Award Period: 7/1/2022 - 6/30/2023 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters (Noncompliance) Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement standards. Condition: The Board of Education’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None noted. Context: Although the Board of Education did not have a policy in place in conformity with the federal uniform guidance criteria, the Board of Education did follow their purchasing policies. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: With the absence of a compliant policy, the Board of Education is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No Recommendation: We recommend that the Board of Education review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and is in process of developing a formal policy.
Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555 Federal Award Identification Number and Year: 12060-SDE64370-20560 Pass-Through Agency: State Department of Education Pass-Through Number(s): N/A Award Period: 7/1/2022 - 6/30/2023 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters (Noncompliance) Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement standards. Condition: The Board of Education’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None noted. Context: Although the Board of Education did not have a policy in place in conformity with the federal uniform guidance criteria, the Board of Education did follow their purchasing policies. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: With the absence of a compliant policy, the Board of Education is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No Recommendation: We recommend that the Board of Education review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and is in process of developing a formal policy.
Federal Agency: Department of the Treasury, Department of Agriculture and Department of Transportation Federal Program Name: American Rescue Plan Act, Child Nutrition Cluster, and Highway Planning and Construction Assistance Listing Number: 21.027,10.553/10.555, and 20.205 Federal Award Identification Number and Year: 12060-OPM20600-29669, 12060-SDE64370-20560 and 12062-DOT57191-22108 Pass-Through Agency: Office of Policy and Management and State Department of Education and State Department of Transportation Pass-Through Number(s): N/A Award Period: 7/1/2022 - 6/30/2023 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters (Noncompliance) Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement standards. Condition: The Board of Education’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None noted. Context: Although the Board of Education did not have a policy in place in conformity with the federal uniform guidance criteria, the Board of Education did follow their purchasing policies. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: With the absence of a compliant policy, the Board of Education is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No Recommendation: We recommend that the Board of Education review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and is in process of developing a formal policy.
Federal Agency: Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555 Federal Award Identification Number and Year: 12060-SDE64370-20560 Pass-Through Agency: State Department of Education Pass-Through Number(s): N/A Award Period: 7/1/2022 - 6/30/2023 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters (Noncompliance) Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement standards. Condition: The Board of Education’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None noted. Context: Although the Board of Education did not have a policy in place in conformity with the federal uniform guidance criteria, the Board of Education did follow their purchasing policies. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: With the absence of a compliant policy, the Board of Education is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No Recommendation: We recommend that the Board of Education review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and is in process of developing a formal policy.
Federal Agency: Department of the Treasury, Department of Agriculture and Department of Transportation Federal Program Name: American Rescue Plan Act, Child Nutrition Cluster, and Highway Planning and Construction Assistance Listing Number: 21.027,10.553/10.555, and 20.205 Federal Award Identification Number and Year: 12060-OPM20600-29669, 12060-SDE64370-20560 and 12062-DOT57191-22108 Pass-Through Agency: Office of Policy and Management and State Department of Education and State Department of Transportation Pass-Through Number(s): N/A Award Period: 7/1/2022 - 6/30/2023 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters (Noncompliance) Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement standards. Condition: The Board of Education’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None noted. Context: Although the Board of Education did not have a policy in place in conformity with the federal uniform guidance criteria, the Board of Education did follow their purchasing policies. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: With the absence of a compliant policy, the Board of Education is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No Recommendation: We recommend that the Board of Education review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and is in process of developing a formal policy.
Federal Agency: Department of the Treasury, Department of Agriculture and Department of Transportation Federal Program Name: American Rescue Plan Act, Child Nutrition Cluster, and Highway Planning and Construction Assistance Listing Number: 21.027,10.553/10.555, and 20.205 Federal Award Identification Number and Year: 12060-OPM20600-29669, 12060-SDE64370-20560 and 12062-DOT57191-22108 Pass-Through Agency: Office of Policy and Management and State Department of Education and State Department of Transportation Pass-Through Number(s): N/A Award Period: 7/1/2022 - 6/30/2023 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters (Noncompliance) Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement standards. Condition: The Board of Education’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None noted. Context: Although the Board of Education did not have a policy in place in conformity with the federal uniform guidance criteria, the Board of Education did follow their purchasing policies. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: With the absence of a compliant policy, the Board of Education is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No Recommendation: We recommend that the Board of Education review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and is in process of developing a formal policy.
Federal Agency: Department of the Treasury, Department of Agriculture and Department of Transportation Federal Program Name: American Rescue Plan Act, Child Nutrition Cluster, and Highway Planning and Construction Assistance Listing Number: 21.027,10.553/10.555, and 20.205 Federal Award Identification Number and Year: 12060-OPM20600-29669, 12060-SDE64370-20560 and 12062-DOT57191-22108 Pass-Through Agency: Office of Policy and Management and State Department of Education and State Department of Transportation Pass-Through Number(s): N/A Award Period: 7/1/2022 - 6/30/2023 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters (Noncompliance) Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement standards. Condition: The Board of Education’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None noted. Context: Although the Board of Education did not have a policy in place in conformity with the federal uniform guidance criteria, the Board of Education did follow their purchasing policies. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: With the absence of a compliant policy, the Board of Education is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No Recommendation: We recommend that the Board of Education review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and is in process of developing a formal policy.
Federal Agency: Department of the Treasury, Department of Agriculture and Department of Transportation Federal Program Name: American Rescue Plan Act, Child Nutrition Cluster, and Highway Planning and Construction Assistance Listing Number: 21.027,10.553/10.555, and 20.205 Federal Award Identification Number and Year: 12060-OPM20600-29669, 12060-SDE64370-20560 and 12062-DOT57191-22108 Pass-Through Agency: Office of Policy and Management and State Department of Education and State Department of Transportation Pass-Through Number(s): N/A Award Period: 7/1/2022 - 6/30/2023 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters (Noncompliance) Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement standards. Condition: The Board of Education’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None noted. Context: Although the Board of Education did not have a policy in place in conformity with the federal uniform guidance criteria, the Board of Education did follow their purchasing policies. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: With the absence of a compliant policy, the Board of Education is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No Recommendation: We recommend that the Board of Education review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and is in process of developing a formal policy.
Federal Agency: Department of the Treasury, Department of Agriculture and Department of Transportation Federal Program Name: American Rescue Plan Act, Child Nutrition Cluster, and Highway Planning and Construction Assistance Listing Number: 21.027,10.553/10.555, and 20.205 Federal Award Identification Number and Year: 12060-OPM20600-29669, 12060-SDE64370-20560 and 12062-DOT57191-22108 Pass-Through Agency: Office of Policy and Management and State Department of Education and State Department of Transportation Pass-Through Number(s): N/A Award Period: 7/1/2022 - 6/30/2023 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters (Noncompliance) Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement standards. Condition: The Board of Education’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None noted. Context: Although the Board of Education did not have a policy in place in conformity with the federal uniform guidance criteria, the Board of Education did follow their purchasing policies. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: With the absence of a compliant policy, the Board of Education is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No Recommendation: We recommend that the Board of Education review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and is in process of developing a formal policy.
Federal Agency: Department of the Treasury, Department of Agriculture and Department of Transportation Federal Program Name: American Rescue Plan Act, Child Nutrition Cluster, and Highway Planning and Construction Assistance Listing Number: 21.027,10.553/10.555, and 20.205 Federal Award Identification Number and Year: 12060-OPM20600-29669, 12060-SDE64370-20560 and 12062-DOT57191-22108 Pass-Through Agency: Office of Policy and Management and State Department of Education and State Department of Transportation Pass-Through Number(s): N/A Award Period: 7/1/2022 - 6/30/2023 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters (Noncompliance) Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement standards. Condition: The Board of Education’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None noted. Context: Although the Board of Education did not have a policy in place in conformity with the federal uniform guidance criteria, the Board of Education did follow their purchasing policies. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: With the absence of a compliant policy, the Board of Education is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No Recommendation: We recommend that the Board of Education review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and is in process of developing a formal policy.
Federal Agency: Department of the Treasury, Department of Agriculture and Department of Transportation Federal Program Name: American Rescue Plan Act, Child Nutrition Cluster, and Highway Planning and Construction Assistance Listing Number: 21.027,10.553/10.555, and 20.205 Federal Award Identification Number and Year: 12060-OPM20600-29669, 12060-SDE64370-20560 and 12062-DOT57191-22108 Pass-Through Agency: Office of Policy and Management and State Department of Education and State Department of Transportation Pass-Through Number(s): N/A Award Period: 7/1/2022 - 6/30/2023 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters (Noncompliance) Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement standards. Condition: The Board of Education’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None noted. Context: Although the Board of Education did not have a policy in place in conformity with the federal uniform guidance criteria, the Board of Education did follow their purchasing policies. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: With the absence of a compliant policy, the Board of Education is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No Recommendation: We recommend that the Board of Education review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and is in process of developing a formal policy.
Federal Agency: Department of the Treasury, Department of Agriculture and Department of Transportation Federal Program Name: American Rescue Plan Act, Child Nutrition Cluster, and Highway Planning and Construction Assistance Listing Number: 21.027,10.553/10.555, and 20.205 Federal Award Identification Number and Year: 12060-OPM20600-29669, 12060-SDE64370-20560 and 12062-DOT57191-22108 Pass-Through Agency: Office of Policy and Management and State Department of Education and State Department of Transportation Pass-Through Number(s): N/A Award Period: 7/1/2022 - 6/30/2023 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters (Noncompliance) Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires compliance with the provisions of procurement standards. Condition: The Board of Education’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned Costs: None noted. Context: Although the Board of Education did not have a policy in place in conformity with the federal uniform guidance criteria, the Board of Education did follow their purchasing policies. Cause: The policy has not been updated to be in compliance with uniform guidance requirements. Effect: With the absence of a compliant policy, the Board of Education is at risk for noncompliance as it relates to federal procurement. Repeat Finding: No Recommendation: We recommend that the Board of Education review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding and is in process of developing a formal policy.
Federal Agency: U.S. Department of Education Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund Assistance Listing Number: 84.425D & 84.425C Federal Award Identification Number and Year: 2021 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165 Award Period: March 13, 2020 through September 30, 2029 & July 1, 2020 through September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or specific requirement: For contracts between federal award recipients and contracts that are subject to David-Bacon Act requirements, 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(I)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions) and 2 CFR Part 176, Subpart C; and 2 CFR section 200.326 require the contractor or subcontractor submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Condition: Both of the qualifying projects selected for testing for compliance with requirements of the Davis-Bacon Act for the submission of weekly certified payrolls by the contractor. The District did not obtain or review weekly payrolls for either contract subject to Davis-Bacon Act provisions. For both contracts certified payrolls were subsequently obtained supporting related weekly payroll. Questioned costs: None Context: The District entered into agreements during the fiscal year under audit for project that were below the scope the contractor and District require full contracts, which included establishing submission and monitoring requirements for weekly certified payrolls. As the District does not commonly entered into contracts subject to these requirements, policies and process in place did not address these requirements. Cause: The District did not design and implement controls to ensure weekly certified payrolls were completed by the contractor and submitted to the District contracts qualifying for Davis-Bacon Act provisions. Effect: Projects subject to compliance with provisions of the Davis-Bacon Act may not be in compliance with required provision for required weekly pay.. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend the District design and implement internal controls that ensure required documentation of weekly certified payrolls are obtained and reviewed for all contracts subject to compliance with Davis-Bacon Act. Views of responsible officials: There is no disagreement with the audit finding. Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund Assistance Listing Number: 84.425D & 84.425C Federal Award Identification Number and Year: 2021 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165 Award Period: March 13, 2020 through September 30, 2029 & July 1, 2020 through September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or specific requirement: For contracts between federal award recipients and contracts that are subject to David-Bacon Act requirements, 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(I)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions) and 2 CFR Part 176, Subpart C; and 2 CFR section 200.326 require the contractor or subcontractor submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Condition: Both of the qualifying projects selected for testing for compliance with requirements of the Davis-Bacon Act for the submission of weekly certified payrolls by the contractor. The District did not obtain or review weekly payrolls for either contract subject to Davis-Bacon Act provisions. For both contracts certified payrolls were subsequently obtained supporting related weekly payroll. Questioned costs: None Context: The District entered into agreements during the fiscal year under audit for project that were below the scope the contractor and District require full contracts, which included establishing submission and monitoring requirements for weekly certified payrolls. As the District does not commonly entered into contracts subject to these requirements, policies and process in place did not address these requirements. Cause: The District did not design and implement controls to ensure weekly certified payrolls were completed by the contractor and submitted to the District contracts qualifying for Davis-Bacon Act provisions. Effect: Projects subject to compliance with provisions of the Davis-Bacon Act may not be in compliance with required provision for required weekly pay.. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend the District design and implement internal controls that ensure required documentation of weekly certified payrolls are obtained and reviewed for all contracts subject to compliance with Davis-Bacon Act. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund Assistance Listing Number: 84.425D & 84.425C Federal Award Identification Number and Year: 2021 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165 Award Period: March 13, 2020 through September 30, 2029 & July 1, 2020 through September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or specific requirement: For contracts between federal award recipients and contracts that are subject to David-Bacon Act requirements, 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(I)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions) and 2 CFR Part 176, Subpart C; and 2 CFR section 200.326 require the contractor or subcontractor submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Condition: Both of the qualifying projects selected for testing for compliance with requirements of the Davis-Bacon Act for the submission of weekly certified payrolls by the contractor. The District did not obtain or review weekly payrolls for either contract subject to Davis-Bacon Act provisions. For both contracts certified payrolls were subsequently obtained supporting related weekly payroll. Questioned costs: None Context: The District entered into agreements during the fiscal year under audit for project that were below the scope the contractor and District require full contracts, which included establishing submission and monitoring requirements for weekly certified payrolls. As the District does not commonly entered into contracts subject to these requirements, policies and process in place did not address these requirements. Cause: The District did not design and implement controls to ensure weekly certified payrolls were completed by the contractor and submitted to the District contracts qualifying for Davis-Bacon Act provisions. Effect: Projects subject to compliance with provisions of the Davis-Bacon Act may not be in compliance with required provision for required weekly pay.. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend the District design and implement internal controls that ensure required documentation of weekly certified payrolls are obtained and reviewed for all contracts subject to compliance with Davis-Bacon Act. Views of responsible officials: There is no disagreement with the audit finding. Federal Program Name: Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund Assistance Listing Number: 84.425D & 84.425C Federal Award Identification Number and Year: 2021 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2022-401253-DPI-ESSERFII-163 & 2022-401253-DPI-ESSERFIII-165 Award Period: March 13, 2020 through September 30, 2029 & July 1, 2020 through September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Criteria or specific requirement: For contracts between federal award recipients and contracts that are subject to David-Bacon Act requirements, 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(I)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions) and 2 CFR Part 176, Subpart C; and 2 CFR section 200.326 require the contractor or subcontractor submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Condition: Both of the qualifying projects selected for testing for compliance with requirements of the Davis-Bacon Act for the submission of weekly certified payrolls by the contractor. The District did not obtain or review weekly payrolls for either contract subject to Davis-Bacon Act provisions. For both contracts certified payrolls were subsequently obtained supporting related weekly payroll. Questioned costs: None Context: The District entered into agreements during the fiscal year under audit for project that were below the scope the contractor and District require full contracts, which included establishing submission and monitoring requirements for weekly certified payrolls. As the District does not commonly entered into contracts subject to these requirements, policies and process in place did not address these requirements. Cause: The District did not design and implement controls to ensure weekly certified payrolls were completed by the contractor and submitted to the District contracts qualifying for Davis-Bacon Act provisions. Effect: Projects subject to compliance with provisions of the Davis-Bacon Act may not be in compliance with required provision for required weekly pay.. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend the District design and implement internal controls that ensure required documentation of weekly certified payrolls are obtained and reviewed for all contracts subject to compliance with Davis-Bacon Act. Views of responsible officials: There is no disagreement with the audit finding.
U.S. Department of Treasury Federal Financial Assistance Listing 21.027 Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension & Debarment Significant Deficiency in Internal Control over Compliance Criteria – The Uniform Guidance, Section 200.303 Internal Controls, requires the non-federal entity establish and maintain effective internal controls over federal awards that provide reasonable assurance that awards are being managed in compliance with federal statutes, regulations and the terms and conditions of the federal award. As described in the 2023 compliance supplement, Part 3 includes the requirements of uniform guidance and 2 CFR sections 200.317 through 200.326. We consider factors such as the County’s internal controls and the internal controls over compliance requirements and tests as prescribed in 2 CFR section 200.317 through 200.326. Condition – We selected 4 procurements during our review of overall grant activity for the year ended June 30, 2023. We noted the following in our testing: 1 of the 4 procurements tested was not purchased prior to publishing bids within the local newspaper as required by the County’s Procurement Policy. Cause – Due to insufficient controls over the procurement review process (documentation) the controls are not operating as designed (or not properly implemented to prevent, detect and correct errors timely). Effect – Failure to document the required procurement procedures of the grant may result in noncompliance with the County’s policy. Questioned Costs – None reported. Context/Sampling – A nonstatistical sample of 4 out of 18 expenditures subject to procurement requirements were selected for testing, which accounted for $320,725 of $1,131,449 total expenditures subject to procurement requirements. Repeat Finding from Prior Years – No. Recommendation – We recommend that the County review the procurement approval process to determine why the controls failed and to design and implement controls that will prevent, detect and correct this from occurring in the future. View of Responsible Officials – The County will be more diligent in following their procurement policy. The Finance Department and Grants Team will provide training and guidance to ensure all the other County Departments/Offices are aware of the requirements. Additionally, the upcoming move to a new financial system will lend itself to policy updates and business process updates to ensure this will be less likely to happen.
U.S. Department of Treasury Federal Financial Assistance Listing 21.027 Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension & Debarment Significant Deficiency in Internal Control over Compliance Criteria – The Uniform Guidance, Section 200.303 Internal Controls, requires the non-federal entity establish and maintain effective internal controls over federal awards that provide reasonable assurance that awards are being managed in compliance with federal statutes, regulations and the terms and conditions of the federal award. As described in the 2023 compliance supplement, Part 3 includes the requirements of uniform guidance and 2 CFR sections 200.317 through 200.326. We consider factors such as the County’s internal controls and the internal controls over compliance requirements and tests as prescribed in 2 CFR section 200.317 through 200.326. Condition – We selected 4 procurements during our review of overall grant activity for the year ended June 30, 2023. We noted the following in our testing: 1 of the 4 procurements tested was not purchased prior to publishing bids within the local newspaper as required by the County’s Procurement Policy. Cause – Due to insufficient controls over the procurement review process (documentation) the controls are not operating as designed (or not properly implemented to prevent, detect and correct errors timely). Effect – Failure to document the required procurement procedures of the grant may result in noncompliance with the County’s policy. Questioned Costs – None reported. Context/Sampling – A nonstatistical sample of 4 out of 18 expenditures subject to procurement requirements were selected for testing, which accounted for $320,725 of $1,131,449 total expenditures subject to procurement requirements. Repeat Finding from Prior Years – No. Recommendation – We recommend that the County review the procurement approval process to determine why the controls failed and to design and implement controls that will prevent, detect and correct this from occurring in the future. View of Responsible Officials – The County will be more diligent in following their procurement policy. The Finance Department and Grants Team will provide training and guidance to ensure all the other County Departments/Offices are aware of the requirements. Additionally, the upcoming move to a new financial system will lend itself to policy updates and business process updates to ensure this will be less likely to happen.
U.S. Department of Treasury Federal Financial Assistance Listing 21.027 Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension & Debarment Significant Deficiency in Internal Control over Compliance Criteria – The Uniform Guidance, Section 200.303 Internal Controls, requires the non-federal entity establish and maintain effective internal controls over federal awards that provide reasonable assurance that awards are being managed in compliance with federal statutes, regulations and the terms and conditions of the federal award. As described in the 2023 compliance supplement, Part 3 includes the requirements of uniform guidance and 2 CFR sections 200.317 through 200.326. We consider factors such as the County’s internal controls and the internal controls over compliance requirements and tests as prescribed in 2 CFR section 200.317 through 200.326. Condition – We selected 4 procurements during our review of overall grant activity for the year ended June 30, 2023. We noted the following in our testing: 1 of the 4 procurements tested was not purchased prior to publishing bids within the local newspaper as required by the County’s Procurement Policy. Cause – Due to insufficient controls over the procurement review process (documentation) the controls are not operating as designed (or not properly implemented to prevent, detect and correct errors timely). Effect – Failure to document the required procurement procedures of the grant may result in noncompliance with the County’s policy. Questioned Costs – None reported. Context/Sampling – A nonstatistical sample of 4 out of 18 expenditures subject to procurement requirements were selected for testing, which accounted for $320,725 of $1,131,449 total expenditures subject to procurement requirements. Repeat Finding from Prior Years – No. Recommendation – We recommend that the County review the procurement approval process to determine why the controls failed and to design and implement controls that will prevent, detect and correct this from occurring in the future. View of Responsible Officials – The County will be more diligent in following their procurement policy. The Finance Department and Grants Team will provide training and guidance to ensure all the other County Departments/Offices are aware of the requirements. Additionally, the upcoming move to a new financial system will lend itself to policy updates and business process updates to ensure this will be less likely to happen.
Finding 2023-003 – COVID 19 – Coronavirus State and Local Fiscal Recovery Fund - AL No. 21.027 U.S. Department of Treasury Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Criteria: Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use 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 Part 200. As governmental subrecipients of states they are also required to use the same state procurement policies and procedures for federal funds as for non‐federal funds, the Town is required to follow Massachusetts General Laws, Chapter (MGL) 30(b). MGL 30(b) requires the solicitation of three written or oral quotes for procurements of supplies between $10,000 and $49,999 and sealed bids or proposals for procurements of supplies $50,000 and over. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. However, A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context: During fiscal year 2023, the Town did not comply with the required procurement policies and procedures in place as it related to one of the expenses charged to the major program. As the expense tested was for engineering services that would have been exempt under Massachusetts General Laws, Chapter (MGL) 30(b) (State Procurement Requirement), under federal statutes and procurement requirements for engineering services identified in 2 CFR Part 200, the Town would have been required to go out to bid for the services. Questioned Costs: $413,477.78. Cause: The noncompliance occurred because the organization mistakenly relied on Massachusetts Chapter 30B exemptions, which govern state and local procurements, and did not recognize the need to comply with the more stringent federal procurement requirements for federal fund usage. Staff members were not sufficiently aware of the specific requirements under 2 CFR Part 200 and the precedence of federal procurement regulations over state law in this context. Effect or Potential Effect: There is risk that amounts charged to the federal awards major program may not be in accordance with procurement, suspension, and debarment principles. Identification as a Repeat Finding: N/A Recommendation: The Town of Bellingham should address the nocompliance and material weakness in internal controls noted above in order to ensure that procurements are conducted in accordance with federal and state requirements. Management Response: We acknowledge the audit finding regarding our reliance on Massachusetts Chapter 30B exemptions for procurement involving federal funds. We understand that federal procurement regulations under 2 CFR Part 200 take precedence over state law and that we failed fully to comply with federal requirements for competitive bidding, sole-source justification, and documentation. We are committed to addressing this issue by reviewing our procurement policies to clearly differentiate between state and federal requirements, ensuring that federal standards govern all procurement involving federal funds. We will provide additional training to staff, implement stronger documentation procedures, and review past procurement to ensure full compliance moving forward.
Finding No. 2023-003 Procurement Federal Agency: U.S. Department of Agriculture; U.S. Department of Education; U.S. Department of the Treasury Federal Program Name: Child Nutrition Cluster; Special Education Cluster (IDEA); Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 10.CNC; 84.027/84.173; 21.027 Federal Award Identification Number and Year: 214RI306N1199 – 2023; H027A220054 – 2023; SLFRP4547 – 2021 Pass-Through Agency: RI Department of Elementary and Secondary Education, RI Department of Revenue Pass-Through Number(s): 2725-13202-301; 12060-OPM20600-29669 Award Period: 10/1/22-9/30/23; 7/1/22-6/30/23; 3/3/21-12/31/24 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement The Town and Coventry Public Schools must comply with procurement standards set out at 2 CFR sections 200.303 and 200.318 through 200.326 within Uniform Guidance. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). UG §200.318 General procurement standards. (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. §200.320 states that the non-Federal entity must use one of the prescribed methods of procurement. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in §200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: (1) Micro-purchases. Procurement by micro-purchase is the acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (See the definition of micro-purchase in §200.1). To the maximum extent practicable, the non-Federal entity should distribute micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive price or rate quotations if the non-Federal entity considers the price to be reasonable based on research, experience, purchase history or other information and documents it files accordingly. Purchase cards can be used for micro-purchases if procedures are documented and approved by the non-Federal entity. (2) Small purchase. Procurement by small purchase is the acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a noncompetitive procurement can be used in accordance with §200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids. Bids are publicly solicited, and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. (2) Proposals. Either a fixed price or cost-reimbursement type contract is awarded. Proposals are generally used when conditions are not appropriate for the use of sealed bids. (c) Noncompetitive procurement. There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the allowed circumstances apply. Condition The Town and Coventry Public Schools purchasing policies do not include all elements as outlined in 2 CFR sections 200.303 and 200.318 through 200.326 noted above. Questioned Costs None Context Although the Town’s and Coventry Public Schools purchasing policies do not include all elements as outlined in 2 CFR sections 200.303 and 200.318 through 200.326, we did not identify transactions where contracts were awarded without proper justification in 9 of 9 procurement transactions tested. Cause Management was not aware of the procurement standards set out at 2 CFR sections 200.303 and 200.318 through 200.326 within Uniform Guidance. Effect The Town and Coventry Public Schools are at risk for noncompliance with Federal grants as it relates to procurement. Repeat Finding Yes, repeat of prior year finding 2022-007. Recommendation We recommend that the Town and Coventry Public Schools updates its procurement policy to include all elements identified in 2 CFR sections 200.303 and 200.318 through 200.326. Views of Responsible Officials Management agrees with this finding.
Finding No. 2023-003 Procurement Federal Agency: U.S. Department of Agriculture; U.S. Department of Education; U.S. Department of the Treasury Federal Program Name: Child Nutrition Cluster; Special Education Cluster (IDEA); Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 10.CNC; 84.027/84.173; 21.027 Federal Award Identification Number and Year: 214RI306N1199 – 2023; H027A220054 – 2023; SLFRP4547 – 2021 Pass-Through Agency: RI Department of Elementary and Secondary Education, RI Department of Revenue Pass-Through Number(s): 2725-13202-301; 12060-OPM20600-29669 Award Period: 10/1/22-9/30/23; 7/1/22-6/30/23; 3/3/21-12/31/24 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement The Town and Coventry Public Schools must comply with procurement standards set out at 2 CFR sections 200.303 and 200.318 through 200.326 within Uniform Guidance. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). UG §200.318 General procurement standards. (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. §200.320 states that the non-Federal entity must use one of the prescribed methods of procurement. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in §200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: (1) Micro-purchases. Procurement by micro-purchase is the acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (See the definition of micro-purchase in §200.1). To the maximum extent practicable, the non-Federal entity should distribute micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive price or rate quotations if the non-Federal entity considers the price to be reasonable based on research, experience, purchase history or other information and documents it files accordingly. Purchase cards can be used for micro-purchases if procedures are documented and approved by the non-Federal entity. (2) Small purchase. Procurement by small purchase is the acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a noncompetitive procurement can be used in accordance with §200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids. Bids are publicly solicited, and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. (2) Proposals. Either a fixed price or cost-reimbursement type contract is awarded. Proposals are generally used when conditions are not appropriate for the use of sealed bids. (c) Noncompetitive procurement. There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the allowed circumstances apply. Condition The Town and Coventry Public Schools purchasing policies do not include all elements as outlined in 2 CFR sections 200.303 and 200.318 through 200.326 noted above. Questioned Costs None Context Although the Town’s and Coventry Public Schools purchasing policies do not include all elements as outlined in 2 CFR sections 200.303 and 200.318 through 200.326, we did not identify transactions where contracts were awarded without proper justification in 9 of 9 procurement transactions tested. Cause Management was not aware of the procurement standards set out at 2 CFR sections 200.303 and 200.318 through 200.326 within Uniform Guidance. Effect The Town and Coventry Public Schools are at risk for noncompliance with Federal grants as it relates to procurement. Repeat Finding Yes, repeat of prior year finding 2022-007. Recommendation We recommend that the Town and Coventry Public Schools updates its procurement policy to include all elements identified in 2 CFR sections 200.303 and 200.318 through 200.326. Views of Responsible Officials Management agrees with this finding.