Finding Text
2024-002 Inadequate Policies and Procedures
Federal Agency U.S. Department of the Treasury
Federal Assistance Listing Numbers 21.027 – Coronavirus State and Local Fiscal Recovery Funds
Criteria [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness
Uniform Guidance (§200.302, §200.303) requires entities to maintain written policies and procedures to ensure proper tracking and compliance with federal award requirements.
Condition The District lacks comprehensive, documented policies and procedures governing the administration of federal awards and the tracking of related expenditures. Specifically, there is no formalized guidance to ensure compliance with federal requirements related to allowable costs, procurement, financial reporting, or other Uniform Guidance compliance areas. This finding appears to be a systemic problem.
Cause The District has not developed or implemented a standardized set of policies and procedures addressing all aspects of federal award compliance. Additionally, staff responsible for managing federal funds have not received regular training on Uniform Guidance requirements.
Effect Inadequate oversight and tracking of federal expenditures increases the risk of misreporting federal expenditures, failing to comply with grant terms and conditions, and potentially having to return federal funds due to noncompliance.
Recommendation Management should develop, implement and disseminate comprehensive written policies and procedures that confirm with Uniform Guidance requirements. There should be clear protocols for all relevant compliance requirements and all personnel involved in federal awards administration need to be trained.
Views of responsible officials and planned corrective actions Department managers and others involved in grants will be educated on the importance of understanding the types of grants they are requesting or receiving including any reporting requirements. Accounting staff will assist with the matching of grant revenues and expenses to verify that they are appropriate and in the correct accounting period. A procedure will be implemented to ensure that at year-end, all grant revenues and expenses are double-checked to verify they are posted in the correct period.