Finding 1220795 (2025-001)

Finding 2025-001: U.S. Department of the Treasury Federal Financial Assistance Listing 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Procurement, Suspension, and Debarment Type of Finding: Material Weakness in Internal Controls over Compliance and Material Noncompliance Criteria: 2 CFR 200.327 and Appendix II to part 200 require that certain provisions, including the Davis-Bacon Act and Contract Work Hours and Safety Standards Act (CWHSSA), be included in covered contracts when applicable. Condition: Contract agreements entered into by the County under this federal program did not include the required provisions related to the Davis-Bacon Act and the CWHSSA. Cause: The County did not have an internal control process in place to ensure that all required federal contract provisions, including the Davis-Bacon Act and CWHSSA clauses, were incorporated into applicable agreements. Effect: The omission of the required federal contract provisions noted above may result in noncompliance with federal regulations as contractors may not be held to federally required labor standards. Questioned Costs: None. Context / Sampling: We tested four of 14 agreements subject to procurement in the SLFRF program. Repeat Finding from Prior Year: No Recommendation: We recommend the County implement a control process to ensure that all federally required contract provisions are included in applicable agreements prior to execution. Views of Responsible Officials: Management agrees with the noted finding. Refer to Corrective Action Plan.