Finding 370054 (2021-009)

Material Weakness
Requirement
AB
Questioned Costs
$1
Year
2021
Accepted
2024-02-21
Audit: 291562
Organization: Delaware County (OK)

AI Summary

  • Core Issue: The County improperly claimed $804,695 in payroll costs for federal reimbursement, with significant amounts deemed unallowed under grant requirements.
  • Impacted Requirements: Noncompliance with federal guidelines regarding allowable costs for the Coronavirus Relief Fund, risking future funding and potential repayment of funds.
  • Recommended Follow-Up: Implement robust internal controls and policies to ensure all federal expenditures meet compliance standards and are properly documented.

Finding Text

Finding 2021-009 – Lack of Internal Controls and Noncompliance Over Major Federal Program - Activities Allowed or Unallowed; Allowed Costs/Cost Principles – Coronavirus Relief Fund PASS-THROUGH GRANTOR: Oklahoma Office of Management and Enterprise Services FEDERAL AGENCY: U.S. Department of Treasury ASSISTANCE LISTING: 21.019 FEDERAL PROGRAM NAME: Coronavirus Relief Fund FEDERAL AWARD YEAR: 2021 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles QUESTIONED COSTS: $804,695 Condition: A test of 100% of payroll expenditures reflected program disbursements totaling $804,695 that were not expended in accordance with the Activities Allowed or Unallowed; Allowable Costs/Cost Principles due to ineligible costs. • The County was reimbursed $726,310 for General Government payroll expenditures for the offices of the County Commissioners, County Clerk, County Treasurer, County Assessor, and the County Court Clerk, for the period March 15, 2020, through October 30, 2020, which was determined to be an unallowed cost to mitigate or prevent the spread of COVID-19 in accordance with grant requirements. • The County was reimbursed $78,385 for 911 Trust Authority payroll expenditures, for the period August 15, 2020, through October 30, 2020, which was determined to be an unallowed cost of non-county employees to mitigate or prevent the spread of COVID-19 in accordance with grant requirements. Cause of Condition: Policies and procedures have not been designed and implemented to ensure that the County has proper internal controls over federal grant expenditures and that the expenditures were for an allowable cost. Effect of Condition: This condition resulted in noncompliance with grant requirements. This could hinder the County from receiving future federal funding and could result in the repayment of grants funds to the grantor agency. Recommendation: OSAI recommends the County design and implement policies and procedures to ensure compliance with applicable grant requirements. Management Response: Chairman of the Board of County Commissioners: The Board of County Commissioners will work to ensure federal disbursements comply with federal grant requirements. The County relied on the Oklahoma Office of Management and Enterprise Services to ensure that the County reimbursement request was for eligible expenditures. Criteria: Title 42 United States Code § 801 – Coronavirus relief fund Section 601(d) requires the States, Tribal governments, or units of local government use the funds received to cover only those costs that (1) are necessary expenditures incurred due to the public health emergency with respect to the Coronavirus Disease 2019 (COVID-19); (2) were not accounted for in the budget most recently approved as of March 27, 2020, for the State or government; and (3) were incurred during the period that begins on March 1, 2020, and ends on December 30, 2020. Additionally, CFR § 200.300(a) Internal Controls reads as follows: The Non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal 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). 2 CFR § 200.403 - Factors affecting allowability costs states in part, Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented.

Corrective Action Plan

The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants.

Categories

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Cash Management Eligibility

Other Findings in this Audit

  • 370052 2021-007
    Material Weakness
  • 370053 2021-008
    Material Weakness
  • 370055 2021-010
    Material Weakness
  • 946494 2021-007
    Material Weakness
  • 946495 2021-008
    Material Weakness
  • 946496 2021-009
    Material Weakness
  • 946497 2021-010
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.019 Coronavirus Relief Fund $2.02M
97.039 Hazard Mitigation Grant $13,245
16.034 Coronavirus Emergency Supplemental Funding Program $10,616
97.042 Emergency Management Performance Grants $7,177