Finding 2340 (2023-003)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2023-11-22
Audit: 4002
Organization: Antelope County (NE)
Auditor: 47-0491233

AI Summary

  • Core Issue: Antelope County failed to implement effective internal controls, leading to inaccuracies in the Project and Expenditure report submitted for COVID-19 funding.
  • Impacted Requirements: Compliance with Federal reporting requirements under Title 2 of the U.S. CFR and guidance from the U.S. Department of the Treasury was not met.
  • Recommended Follow-Up: Establish procedures for accurate Federal reporting, including training and a thorough review process by an independent knowledgeable individual.

Finding Text

Program - AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Grant Number & Year - SLFRP3105, March 3, 2021, through December 31, 2024 Federal Grantor Agency - U.S. Department of the Treasury Criteria - Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2023) states the following, in relevant part: The non-Federal entity must: a) 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). The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2023), which states the following: Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200. The U.S. Department of the Treasury issued “Compliance and Reporting Guidance” and frequently asked questions, which specify the reporting requirements related toCoronavirus State and Local Fiscal Recovery Funds. A good internal control plan includes establishing effective internal controls through written policies and procedures to ensure Federal reporting requirements are completed accurately. Such plan should include, among other things, appropriate training on Federal reporting requirements and require a documented, detailed review of each report to be completed by a knowledgeable individual, who did not prepare the report, prior to submission. Condition - Antelope County did not implement effective internal controls to ensure that the reporting requirements of the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) were completed accurately. The Project and Expenditure report submitted on May 1, 2023, did not contain accurate information for multiple expenditure and obligations categories. Repeat Finding - No Questioned Costs - None Statistical Sample - No Cause - Lack of procedures and knowledge relating to Federal reporting requirements. Effect - Inaccurate information was reported to the U.S. Department of the Treasury on the 2023 Project and Expenditure report. Additionally, the there is an increased risk the County is not in compliance with the reporting requirements set by the U.S Department of the Treasury. Recommendation - We recommend the County implement procedures to ensure Federal reporting requirements are completed accurately. Such procedures could include, among other things, appropriate training on Federal reporting requirements and a documented review by a knowledgeable individual who was not involved in the preparation of the report. View of Officials - Antelope County will complete the annual expenditure report as required by ARPA Funding.

Corrective Action Plan

Antelope County will complete the annual expenditure report as required by ARPA Funding.

Categories

Allowable Costs / Cost Principles Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 2339 2023-002
    Significant Deficiency
  • 578781 2023-002
    Significant Deficiency
  • 578782 2023-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.22M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $315,579
93.563 Child Support Enforcement $13,385