Finding Text
Criteria: Requirements per 2 CFR Section 200.303 of the Uniform Guidance state that non-federal entities must establish and maintain effective internal control over federal awards to provide reasonable assurance that the nonfederal entity is managing the federal award in accordance with federal statutes, regulations, and terms and conditions of the awards received. Condition: Management had not established an adequate system of internal control over compliance with the relevant federal statutes, regulations, and terms and conditions of the federal awards as management?s internal control procedures did not cause the entity to retain documentation supporting compliance with the Procurement requirements under the Emergency Connectivity Fund Program and the Special Tests and Provisions requirements under the Elementary and Secondary School Emergency Relief Fund. Cause: Management did not retain appropriate documentation to support obtaining price or rate quotations from an adequate number of qualified sources in accordance with 2 CFR section 200.320(b). Management also did not retain appropriate documentation to support compliance with wage rate requirements established under 29 CFR Part 5. Effect or Potential Effect: Without appropriate documentation, non-compliance could occur which the entity may not identify. We were not able to determine if the entity was in compliance with these compliance requirements. Questioned Costs: N/A Recommendation: Management should retain documentation to support proper operation of internal controls over compliance and compliance with applicable Federal statutes, regulations, and terms and conditions of the awards received. Views of Responsible Officials: We are in agreement with the finding and GCCS management will retain documentation to support proper operation of internal controls and compliance with applicable Federal statutes, regulations, and terms and conditions of the awards received. Auditor?s Evaluation of the Views of Responsible Officials: Management?s response is appropriate to address the finding. If properly implemented, management?s response would include procedures to prevent reoccurrence in the future.