Finding 1236242 (2025-004)

Material Weakness Repeat Finding
Requirement
BCIL
Questioned Costs
-
Year
2025
Accepted
2026-09-23
Audit: 411842
Organization: Pipestone County (MN)
Auditor: ABDO LLP

AI Summary

  • Core Issue: The County lacks formal written policies for managing Federal awards, leading to potential compliance risks.
  • Impacted Requirements: Compliance with Uniform Guidance (2 CFR § 200.318 and § 200.303) regarding procurement and internal controls is not being met.
  • Recommended Follow-Up: Develop and approve a comprehensive federal expenditures policy that covers all necessary compliance areas.

Finding Text

Section III – Federal Award Findings and Questioned Costs 2025-004 Federal Awards Internal Control Policy and Procedures Federal Agency: U.S. Department of Transportation Program Name: Highway Planning and Construction ALN: 20.205 Award Number & Year: STBG 5925(127), 2025 Pass-Through Agency: Minnesota Department of Transportation Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria: Uniform Guidance requires non-Federal entities to use and document procurement procedures applicable to Federal awards (2 CFR § 200.318(a)). In addition, non-Federal entities must maintain written standards of conduct covering conflicts of interest and governing the actions of employees engaged in the selection, award, and administration of contracts supported by Federal funds (2 CFR § 200.318(c)(1)). Uniform Guidance further requires non-Federal entities to establish and maintain effective internal control over Federal awards that provides reasonable assurance of compliance with Federal statutes, regulations, and the terms and conditions of Federal awards (2 CFR § 200.303). These requirements contemplate the adoption and implementation of written procurement policies and procedures governing procurements charged to Federal awards. Condition: The County had not established and formally adopted written policies and procedures governing the administration of Federal awards and compliance with Uniform Guidance requirements. Specifically, written guidance addressing key compliance areas such as allowable costs, procurement, reporting, subrecipient monitoring, cash management, and records retention had not been developed or approved by the County Board. Questioned Costs: None. Context: As part of our evaluation of internal controls over compliance and compliance with Uniform Guidance, we assessed whether the County had documented policies and procedures governing the administration of Federal awards. Cause: County management had not established a process to develop and obtain approval of a comprehensive Federal awards policy. Effect: Without an approved Federal expenditures policy, there is an increased risk that Federal awards may not be administered consistently in accordance with Uniform Guidance requirements. This could result in noncompliance with applicable Federal regulations and increase the likelihood that compliance requirements are not identified, communicated, or monitored appropriately. Recommendation: We recommend the County develop, formally approve, and implement a federal expenditures policy that addresses applicable Uniform Guidance requirements, including internal controls over compliance, allowable costs, cash management, procurement, subrecipient monitoring, reporting, and record retention. Repeat Finding: No. View of Responsible Officials: Acknowledged.

Corrective Action Plan

Finding Number: 2025-004 Finding Title: Federal Awards Internal Control Policy and Procedures 1. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding: County management will develop and formally adopt a federal expenditures policy to establish procedures for administering and monitoring federal awards in accordance with Uniform Guidance requirements. The policy will address internal controls over compliance, allowable costs, reporting requirements, record retention, and other applicable federal compliance requirements. Management will also communicate the policy to appropriate personnel responsible for administering federal programs. 3. Official Responsible for Ensuring CAP: Steve Ewing, County Administrator, is the official responsible for ensuring corrective action plan. 4. Planning Completion Date for CAP: 12/31/2026 5. Plan to Monitor Completion of CAP: County management will review the policy periodically to ensure it remains current with federal requirements and will monitor compliance with the policy through the administration and oversight of federal programs.

Categories

Subrecipient Monitoring Procurement, Suspension & Debarment Allowable Costs / Cost Principles Cash Management Reporting Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
20.205 HIGHWAY PLANNING AND CONSTRUCTION $2.13M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $75,694
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $21,139
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $1,041