Finding Text
Item 2023‐002 Written policies, procedures, and standards of conduct
COVID 19 – Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number 21.027
U.S. Department of Treasury
Grant period: Year ended September 30, 2023
Questioned Costs – $0
Condition – The City does not have all of the written policies, procedures and standards of conduct
required by UG.
Criteria – 2 CFR 200.303 requires the non‐Federal entity to “(a) establish and maintain effective
internal controls over the Federal award that provides reasonable assurance that the non‐Federal
entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal
award.” Grantees should have written policies, procedures, and standards of conduct as required by
2 CFR 200, Subparts D & E of the Uniform Guidance. 2 CFR 200, Subparts D & E requires the non‐
Federal entity to establish and maintain written policies, procedures, and standards of conduct
including internal controls over the Federal awards that provides reasonable assurance that the non‐
Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the
Federal award. Specific requirements relate to the following:
§ 200.302 Financial management
§ 200.305 Payment § 200.319 Competition
§ 200.320 Methods of procurement to be followed
§ 200.430 Compensation—personal services
§ 200.431 Compensation—fringe benefits
Cause of Condition – The City has failed to prepare written policies, procedures, and standards of
conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance.
Potential Effect of Condition – Lack of written policies, procedures, and standards of conduct could
result in noncompliance related to federal awards.
Recommendation – We recommend that the City implement the required written policies and
procedures.
Management’s Response – Management agrees with the finding and will implement the necessary
written policies to comply with the UG. Management anticipates completion by September 30, 2024.