Finding 381076 (2022-014)

Material Weakness
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2024-03-19
Audit: 295825
Organization: Comanche County (OK)

AI Summary

  • Core Issue: The County misclassified contractors as subrecipients and inaccurately reported federal expenditures, leading to noncompliance with grant requirements.
  • Impacted Requirements: Reporting standards for the Coronavirus State and Local Fiscal Recovery Funds were not met, resulting in an understatement of federal expenditures by $221,261.
  • Recommended Follow-Up: The County should implement internal controls and ensure understanding of compliance requirements to prevent future reporting errors.

Finding Text

Finding 2022-014 – Noncompliance with Reporting Requirements Over Federal Grant – Coronavirus State and Local Fiscal Recovery Funds PASS-THROUGH GRANTOR: Direct Grant FEDERAL AGENCY: U.S. Department of Treasury ASSISTANCE LISTING: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds FEDERAL AWARD YEAR: 2021 CONTROL CATEGORY: Reporting QUESTIONED COSTS: $0 Condition: The test of 100% of Coronavirus State and Local Fiscal Recovery Funds expenditures reflected that an incorrect classification category was used for contractors. The quarterly reports that were filed listed the contractors as subrecipients. Further, expenditures for federal programs were not adequately reported on the CSLFRF Compliance Reports. Federal expenditures were understated by $221,261. The following misstatements were noted: • The actual expenditures to vendors totaled $161,634 and the County reported $180,710, resulting in an overstatement of $19,076. • The actual expenditures to subrecipients totaled $404,257 and the County reported $403,909, resulting in an understatement of $348. • The actual expenditures paid to county employees for premium pay and employee benefits were $1,300,148 and the County reported $1,060,159, resulting in an understatement of $239,989. Reported Total Expenditures of Federal Awards $ 1,644,812 Add: Expenditures to Subrecipients 348 Add: Expenditures for Premium Pay 239,989 Less: Expenditures to Vendors (19,076) Actual Federal Expenditures of Federal Awards 1,866,073 Reporting Understated by $ 221,261 Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with federal compliance requirements. Effect of Condition: This condition resulted in noncompliance to grant requirements. Recommendation: OSAI recommends the County gain an understanding of the requirements for this program and implement internal controls to ensure compliance with these requirements. Management Response: Chairman of the Board of County Commissioners: The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants. Criteria: Coronavirus State and Local Fiscal Recovery Funds Guidance on Recipient Compliance and Reporting Responsibilities reads as follows: 10. Reporting. All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, your organization needs to establish controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. See Part 2 of this guidance for a full overview of recipient reporting responsibilities. Further, 2 CFR § 200.329 Monitoring and Reporting Program Performance (c)(1) reads as follows: The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date. A subrecipient must submit to the pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance reports as required by the terms and conditions of the Federal award. See also § 200.344. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any performance report.

Corrective Action Plan

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

Categories

Subrecipient Monitoring Period of Performance Reporting

Other Findings in this Audit

  • 381074 2022-006
    Material Weakness
  • 381075 2022-007
    Material Weakness
  • 381077 2022-015
    Material Weakness
  • 957516 2022-006
    Material Weakness
  • 957517 2022-007
    Material Weakness
  • 957518 2022-014
    Material Weakness
  • 957519 2022-015
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.87M
15.226 Payments in Lieu of Taxes $172,429
97.042 Emergency Management Performance Grants $40,000
10.555 National School Lunch Program $39,355
16.034 Coronavirus Emergency Supplemental Funding Program $31,849
10.553 School Breakfast Program $18,361
16.738 Edward Byrne Memorial Justice Assistance Grant Program $7,615
16.543 Missing Children's Assistance $2,367