Finding Text
Finding Type: Significant deficiency and noncompliance Federal Program(s): Across all the programs Criteria: The Uniform Guidance requires a non-federal entity that has expended federal awards to establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The Council did not have formal written federal policies and procedures that document the processes and controls used to administer federal awards, including procedures for compliance with applicable federal program requirements under Uniform Guidance. Cause: This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance. Effect: Without written federal policies and procedures, there is an increased risk that federal award requirements may not be consistently applied, monitored, or retain as institutional knowledge. Questioned Costs: None Initial year of finding: 2025 Recommendation: We recommend the Council develop and implement written federal policies and procedures addressing the administration of federal awards to ensure compliance with Uniform Guidance. The policies should address the following key compliance areas: allowable costs, cash management, procedures, and conflicts of interest. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.