Finding Text
2023-004 – Written Policies Required by the Uniform Guidance
Finding Type: Material Weakness in Internal Controls and Noncompliance (Allowable Costs/Cost Principles, Cash Management, Procurement and Suspension & Debarment)
Federal Program: U.S. Environmental Protection Agency – Capitalization Grants for Clean Water State Revolving Funds (AL #66.458)
Criteria: The City does not have written policies and procedures to implement the requirements of 2 CFR section 200 for the administration of federal awards. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant on or after December 26, 2014 to have written policies pertaining to: 1) advance payments and reimbursements; 2) determination of allowable costs; 3) compensation (personnel and benefits policies); 4) travel costs; and 5) procurement procedures. 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal controls over the federal awards that provide assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the conditions of the federal award.
Condition: Although the City has processes in place to conform to the requirements in the Uniform Guidance, there are no formal written policies in place.
Cause: The City was unaware of the requirement to have formal written policies for compliance with the Uniform Guidance.
Effect: As a result of this condition, the City did not fully comply with the Uniform Guidance.
Questioned Costs: No costs have been questioned as a result of this finding.
Recommendation: We recommend that the City adopt formal written policies covering these areas as soon as practical, but no later than the end of fiscal year 2024.
Views of Responsible Officials: The City will adopt formal written policies as required by the Uniform Guidance.