Finding 1075310 (2023-001)

CONDITION: During my review of the Borough of Ellwood City’s internal controls over federal awards, I noted that the Borough does not have formal written policies and procedures surrounding the management of their federal award funds. Although not all-inclusive, an example of some of the required polices would include written procedures for procurement, conflict of interest, and allowable costs. CRITERIA: Section 2 CFR 200.303 of the Uniform Guidance requires non-federal entities such as the Borough of Ellwood City to maintain effective internal controls over federal awards. In addition, the Uniform Guidance also recommends these internal controls follow guidance in Standards for Internal Control in the Federal Government (the Green Book), issued by the Comptroller General of the United States. EFFECT: The Borough of Ellwood City is not in compliance with Section 2 CFR 200.303 of the Uniform Guidance which requires non-federal entities to maintain effective internal controls over federal awards. QUESTIONED COST: None CAUSE: It was not readily determinable as to why the Borough of Ellwood City had not formally adopted written policies and procedures surrounding the management of their federal award funds. RECOMMENDATION: I recommend that the Borough of Ellwood City adopt the required written policies and procedures surrounding the management of federal award funds as prescribed by Section 2 CFR 200.303 of the Uniform Guidance. The focus of these policies and procedures should be to ensure that the Borough officials who are responsible for carrying out the objectives of the federal financial award understand 1) the federal statutes, regulations, and terms and conditions of the award, 2) how to evaluate and properly monitor compliance, and 3) the steps to take if noncompliance is identified. VIEWS OF RESPONSIBLE OFFICIALS: The Borough of Ellwood City concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.