PASS THROUGH GRANTOR: Direct Grant; Oklahoma Department of Transportation
FEDERAL AGENCY: U.S. Department of Commerce; U.S. Department of Transportation
ASSISTANCE LISTING: 11.300 and 20.205
FEDERAL PROGRAM NAME: Investments for Public Works and Economic Development Facilities
and Highway Planning and Construction
FEDERAL AWARD NUMBER: ERSTP 262C(075), ERSTP 266C(076), ERSTP 266C(077), and
ERSTP 266C (082)
FEDERAL AWARD YEAR: 2020
CONTROL CATEGORY: All
QUESTIONED COSTS: $-0-
Condition: During our review and reconciliation of the SEFA, as initially prepared by the County, we
identified federal programs that were not reported accurately. These errors resulted in expenditures being
overstated by $299,126.
Cause of Condition: Policies and procedures have not been designed and implemented to ensure accurate
reporting of expenditures for all federal awards.
Effect of Condition: This condition resulted in inaccurate recording of expenditures on the SEFA and
could increase the potential for material noncompliance.
Recommendation: OSAI recommends county officials and department heads gain an understanding of
federal programs awarded to Rogers County. Internal control procedures should be designed and
implemented to ensure an accurate reporting of expenditures on the SEFA and to ensure compliance with
federal requirements.
Management Response:
Board of County Commissioners: The BOCC is responsible for the overall fiscal concerns of the county.
See OKLA. STAT. Title 19, § 345. The BOCC, with the cooperation and participation of all elected officials,
reviews, develops and implements policies and procedures to create a strong internal control environment.
Additionally, the BOCC conducts meetings with all elected officials and officers responsible for the receipt
and/or expenditure of county funds. These meetings address fiscal matters, including but not limited to,
policy discussions and implementation, financial reports, budget oversight, SEFA reporting, and legal
compliance.
Policies and procedures, combined with fiscal oversight meetings, are intended to: 1) prevent or detect
material misstatements in the financial statements; 2) prevent or detect fraud within the county; 3) increase
communication between the BOCC and those elected officials and officers responsible for the receipt and/or
expenditure of public funds; 4) provide oversight over the fiscal concerns of the county; 5) identify and
address risks related to financial reporting; 6) ensure the accuracy of Rogers County’s financial statements,
Estimate of Needs, the SEFA; and 7) ensure compliance with all applicable federal and state laws,
regulations, and/or codes.
The BOCC is responsible for preparing the financial statements. See OKLA. STAT. Title 68, § 3002(A). At
the end of fiscal year 2020, the BOCC chose not to renew the contract with the budget maker. Beginning
in fiscal year 2021, the BOCC and the Rogers County Treasurer developed and implemented a plan for the
preparation and presentation of the financial statements by the Rogers County Treasurer beginning in fiscal
year 2021. The purpose of this plan was to increase communication, involvement and oversight regarding
the County’s financial condition and for better accuracy and timeliness of the preparation and presentation
of the financial statements.
The BOCC, with the cooperation of all elected officials and officers responsible for the receipt or
expenditure of county funds, will evaluate the processes and procedures currently in place to detect and
identify material misstatements in Rogers County’s financial statements, detect fraud, and identify and
address risks related to Rogers County’s financial reporting. Where deficiencies are identified, processes
and procedures will be implemented to identify fraud, detect material misstatements in the financial
statements, and address risks related to financial reporting.
County Clerk: The County Clerk works with the BOCC and all elected officials to develop and implement
policies and procedures to prevent material misstatements in Rogers County’s financial statements, detect
fraud and identify and address risks related to Rogers County’s financial reporting. These policies are
intended to ensure the accuracy of the County’s financial statements, Estimate of Needs, SEFA, and
compliance with all applicable federal and state laws, regulations, and/or codes.
The County Clerk will continue to perform the duties of her office in accordance with Oklahoma law.
Where appropriate, the County Clerk will participate in the development and implementation of policies
and procedures to prevent material misstatements in Rogers County’s financial statements, detect fraud and
identify and address risks related to Rogers County’s financial reporting.
County Treasurer: The County Treasurer was engaged to compile the SEFA report. Each department is
responsible for reporting its own Federal revenues and expenditures.
County Sheriff: The County Sheriff will work with the BOCC and all elected officials to develop and
implement policies and procedures to ensure Rogers County’s SEFA is prepared timely and accurately.
Criteria: GAO Standards – Section 2 – Establishing an Effective Internal Control System – OV2.23 states
in part:
Objectives of an Entity – Compliance Objectives
Management conducts activities in accordance with applicable laws and regulations. As
part of specifying compliance objectives, the entity determines which laws and regulations
apply to the entity. Management is expected to set objectives that incorporate these
requirements.
2 CFR § 200.303(a) Internal Controls reads as follows:
The 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).
2 CFR § 200.508(b) Auditee responsibilities reads as follows:
The auditee must:
Prepare appropriate financial statements, including the schedule of expenditures of Federal
awards in accordance with §200.510 Financial statements.
2 CFR § 200.510(b) Financial statements reads as follows:
Schedule of expenditures of Federal awards.
The auditee must also prepare a schedule of expenditures of Federal awards for the period
covered by the auditee's financial statements which must include the total Federal awards
expended as determined in accordance with §200.502 Basis for determining Federal
awards expended.