Finding Text
The Lawrence County Fiscal Court Did Not Establish And Maintain Effective Internal Controls Over Compliance With Coronavirus State and Local Fiscal Recovery Fund (SLFRF) Requirements Federal Program: Assistance Listing #: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award Number and Year: 2022 Name of Federal Agency: U.S. Department of the Treasury Compliance Requirements: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Reporting Type of Finding: Significant Deficiency Amount of Questioned Costs: $0 COVID Related: Yes The Lawrence County Fiscal Court transferred federal funds from the ARPA fund to the general, jail, road, LGEA, and E-911 funds without first ensuring sufficient supporting documentation of allowable expenditures during the same period as the funds were reported as expended on the Schedule of Expenditures of Federal Awards (SEFA). The county was awarded $2,975,148 in American Rescue Plan Act (ARPA) funds, receiving the first payment of $1,487,618 into the ARPA fund in May 2021, and their second payment of $1,487,530 in June 2022.The fiscal court?s transfers in total from the ARPA fund to each fund are provided below: ? General - $714,640 ? Road - $250,000 ? Jail - $40,000 ? LGEA - $25,000 ? E-911 - $10,000 ? Payroll - $217,739 These transfers from the ARPA fund were considered ?lost revenue? according to their fiscal court meeting minutes. At the time of these transfers, and until auditors inquired about the supporting documentation, the county did not maintain a list of expenditures that reconciled to the transfer total. After this inquiry, the county gathered documentation and provided auditors a reconciliation of expenditures of eligible costs that supported the amount transferred into the general fund. An effective internal control system was not in place in Lawrence County to ensure compliance with requirements related to the administration of ARPA funds and the Allowable Costs/Cost Principles compliance requirements. The lack of internal controls was a systemic issue throughout the period. Failure to establish and maintain effective internal controls over compliance with federal program requirements could subject the county to the risk of reporting ineligible expenditures on the SEFA and using grant funds for unallowable purposes. 2 CFR 200.303 states in part, ?[t]he non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR ?200.302(b) states, ?[t]he financial management system of each non-Federal entity must provide for the following ?: (2) [a]ccurate, current and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set for in ?200.328 and 200.329.? In addition, 2 CFR ?200.502(a) states, ?[t]he determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs.? Therefore, the county should only include expenditures on the Schedule of Expenditures of Federal Awards (SEFA) for which there is sufficient supporting documentation. We recommend the county establish and maintain internal controls over compliance for all federal program expenditures to ensure accurate use and reporting of federal awards, including maintaining sufficient supporting documentation of expenditures that reconciles to any transfer from a federal program fund into other county funds.