Finding Text
2022-001 ? Written Policies and Procedures Required by the Uniform Grant Guidance (Repeat) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles, Cash Management and Procurement, Suspension and Debarment). Program. Community Development Block Grants/Entitlement Grants; ALN Number 14.218; Award Numbers B21-MC-26-0035 and B20-MW-26-0035. Coronavirus State and Local Fiscal Recovery Funds; ALN Number 21.027; Award Numbers CKA9Q3H2PXH7 and SLFRP0127. Reducing Lead in Drinking Water Program (SDWA 1459B); ALN Number 66.443; Award Number 2105PKX003. Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (?200.302 (6)); 2) Procurement (including bidding and a conflict of interest policy) (?200.318); 3) Allowability of costs charged to federal programs (?200.302 (7)); 4) Compensation (personnel and benefits policy) (?200.430 and ?200.431); and 5) Travel costs (including mileage and per diem) (?200.474). Condition. Although the City has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the areas required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the City. Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance. Effect. As a result of this condition, the City did not fully comply with the Uniform Guidance applicable to the above noted grants. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs or excess cash draws. Recommendation. We recommend that the City review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2023. View of Responsible Officials. The City has prepared a policies and procedures manual for the Community Development Block Grant and other federal grant programs, which was approved by the City Commission subsequent to the end of the fiscal year under audit.