Finding 32695 (2022-001)

2022-001: Written Policies - Internal Control Finding Prior Year Findings: None Department Agency: Bureau of Reclamation Assistance Listing Number: ALN # 15.507 Type of Finding: Significant Deficiency Questioned Costs: None Criteria: Uniform Guidance policies require 2 CFR Part 180 states written policies and procedures related to internal controls be written regarding SAMS.gov contractor verification of debarment and suspension. In addition, 200.326 Contract Provisions, require contractors paying over $2,000 in labor wages be compliant with Davis Bacon Labor Laws. This requirement contains written acknowledge of certified wage rate payrolls weekly and contractual language of the wage rate certification of payroll in the contract between the contractor and the Davis & Weber Counties Canal Company. Condition: Davis & Weber Counties Canal Company does not have updated written policies implementing Uniform Guidance contractual and internal control procedures. Cause and Effect: While detailed testing found no unallowed costs, without lack of written internal control polices the Davis & Weber Counties Canal Company could enter into transactions with debarred or suspended vendors, and not pay adequate Federal wage labors. Repeat Finding: No Recommendation: We recommend that the Davis & Weber Counties Canal Company update their written internal control policies to contain all Uniform Guidance regulations, relating to Sams.gov debarment and suspension and Davis Bacon Wage requirements. It is recommended that these polices and internal controls be reviewed in alignment with the Federal Award contractual agreements on a routine basis. Response: Please see the last page of this report for the Davis & Weber Counties Canal Company?s response to this finding.