Finding 48498 (2022-001)

Significant Deficiency
Requirement
P
Questioned Costs
-
Year
2022
Accepted
2023-04-16

AI Summary

  • Core Issue: The Powder River Conservation District lacks updated written policies for compliance with Uniform Guidance, specifically regarding contractor verification and wage requirements.
  • Impacted Requirements: Non-compliance with 2 CFR Part 180 and 200.326 could lead to issues with debarred vendors and inadequate wage payments.
  • Recommended Follow-Up: Update and implement internal control policies that align with Federal grant requirements and include all necessary Uniform Guidance regulations.

Finding Text

2022-001 Uniform Guidance Written Policies and Procedures ? Significant Deficiency Criteria: Uniform Guidance policies requires 2 CFR Part 180, which states written policies and procedures related to internal controls be written regarding SAMS.gov contractor verification of debarment and suspension. In addition, 200.326 Contract Provisions that pay over $2,000 in labor wages require to be in compliant with Davis Bacon Labor Laws. This requirement contains written acknowledge of certified wage rate payrolls weekly and contractual language of the wage rate certification of payroll in the contract between the contractor and the District. Condition: We found that Powder River Conservation District does not have written updated policies implementing Uniform Guidance contractual and internal control procedures. Cause & Effect: The cause appears to be the result of a lack of experience, and the effect is non-compliance and the possibility of entering into transactions with debarred or suspended vendors, and not paying adequate Federal wages to labors. Questioned Costs: -0- Recommendation: We recommend that the District update and implement written internal control policies that coincide with Federal grant requirements and contain all Uniform Guidance regulations, relating to Sams.gov debarment and suspension, Davis-Bacon Wage Requirements and internal controls. Management Response: See the last page of this report for Management?s response as found on the District?s letterhead.

Corrective Action Plan

2022-001 Uniformed Guidance Written Policies and Procedures - Significant Deficiency i. Contact Person Responsible for Action: District Manager Anita Bartlett ii. Corrective Action Planned: The Powder River Conservation District (PRCD) will create a written internal control policy that coincides with federal grant requirements and contains all Uniform Guidance regulations relating to Sams.gov debarment and suspension, Davis-Bacon Wage Requirements, and other internal controls. The PRCD will also insure that district employees receive proper training/education on these regulations. iii. Anticipated Completion Date: December 31, 2023.

Categories

Procurement, Suspension & Debarment Significant Deficiency

Other Findings in this Audit

  • 48499 2022-002
    Material Weakness
  • 624940 2022-001
    Significant Deficiency
  • 624941 2022-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.923 Emergency Watershed Protection Program $908,315
15.608 Fish and Wildlife Management Assistance $75,000