Finding Text
Finding 2024-012 – Lack of Internal Controls Over Major Federal Programs – Highway Planning
and Construction Cluster (Federal-Aid Highway Program)
PASS-THROUGH GRANTOR: Bureau of Indian Affairs FEDERAL AGENCY: U.S. Department of Transportation
ASSISTANCE LISTING: 20.205
FEDERAL PROGRAM NAME: Highway Planning and Construction Cluster (Federal-Aid Highway Program)
FEDERAL AWARD YEAR: 2019
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Matching;
Procurement and Suspension and Debarment; Special Tests and Provisions
QUESTIONED COSTS: $-0-
Condition: During the process of documenting the County’s internal controls regarding federal
disbursements, we noted that the County has not established procedures to ensure compliance with
the following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/Cost
Principles; Matching; Procurement and Suspension and Debarment; Special Tests and Provisions.
Cause of Condition: Policies and procedures have not been designed and implemented to ensure
federal expenditures are made in accordance with federal compliance requirements.
Effect of Condition: This condition could result in noncompliance with grant requirements and could
result in a loss of federal funds to the County.
Recommendation: OSAI recommends the County gain an understanding of requirements for this program
and implement internal control procedures to ensure compliance with requirements.
Management Response:
Chairman of the Board of County Commissioners: The Board of County Commissioners will work with all
County Officials to go over all grants and federal monies that the County receives to ensure that
proper internal controls are implemented.
Criteria: OMB 2 CFR 200, Subpart D. 200.303(a) reads as follows: Subpart D-Post Federal Award
Requirements
§200.303 Internal Controls 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).
Further, accountability and stewardship should be overall goals in management's accounting of
federal funds. Internal controls should be designed to monitor compliance with laws and regulations
pertaining to grant contracts.