Finding 1100661 (2020-003)

FINDING 2020-003 Subject: Water and Waste Disposal Systems for Rural Communities - Reporting Federal Agency: Department of Agriculture Federal Program: Water and Waste Disposal Systems for Rural Communities Assistance Listings Number: 10.760 Federal Award Number and Year (or Other Identifying Number): CY2020 Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context Annual financial reports are to be filed with the awarding agency. The Town was required to file two reports during the audit period, the Statement of Budget, Income and Equity (Form RD 442-2) and the Balance Sheet (Form RD 442-3) with the U.S. Department of Agriculture (USDA). The Form RD 442-2 covers financial operations relating to the Town's water main replacement project and the Form RD 442-3 presents the financial status of the project. In both instances, a borrower may submit the financial data on other forms, provided the forms are in a similar format and signed and dated by the organization's official to certify the correctness of the information. Alternatively, an annual audit may be submitted in lieu of the forms. The Town did not prepare or file the required reports, submit financial data on other forms, or submit an annual audit in lieu of the forms to the USDA. As such, we could not substantiate the financial operations or the financial status of the project. Additionally, the Town did not obtain a written waiver from the USDA to allow the Town not to file the reports. The lack of internal controls and noncompliance were systemic issues, which occurred throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 16 TOWN OF MONROEVILLE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 7 CFR 1780.47(e) states: "Borrowers exempt from audits. All borrowers who are exempt from audits, will, within 60 days following the end of each fiscal year, furnish the RUS with annual financial statements, consisting of a verification of the organization's balance sheet and statement of income and expense by an appropriate official of the organization. Forms RD 442-2, 'Statement of Budget, Income and Equity,' and 442-3 may be used." Cause Management of the Town had not established an effective system of internal controls that segregated key functions and would have ensured compliance with reporting requirements of the grant. As a result, Form 442-2 and Form 442-3 were not filed. The Town did not obtain a written waiver from the USDA to support the reports not being filed. Effect Without the proper implementation of an effectively designed system of internal controls, the Town cannot ensure the required reports were filed with the awarding agency. As such, the USDA does not have accurate and current information to discern the financial status of the Town's project. Furthermore, noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the Town. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the Town's management establish a proper system of internal controls and develop policies and procedures to ensure required reports, or allowable alternatives, are completed and filed with the USDA. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.