Finding 499540 (2023-003)

2023-003 Uniform Guidance Written Policies and Procedures Significant Deficiency in Internal Control over Compliance Criteria Uniform Guidance 2 CFR Part 180 requires written policies and procedures related to Internal controls be written regarding SAMS. gov contractor verification of debarment and suspension. In addition, 2 CFR Part 200.326 Contract Provisions that pay over $2,000 in labor wages are required to be in compliant with Davis Bacon Labor Laws. This requirement contains written achnowledgement of certified wage rate payrolls weekly and contractual language of the wage rate certification of payroll in the contract between the contractor and the Joint Powers Board. Cause Tongue River Valley Joint Powers Board do not have written updated policies implementing Uniform Guidance contractual and internal control procedures. They operate under the WY Statues - which covers entities within Wyoming jurisdiction, however the Joint Powers Board also has Federal requirements due to the Federal USDA loan. Condition Without lack of written policies, the Joint Powers Board could enter transactions with debarred or suspended vendors, and not pay adequate Federal wages to labors. Effect The Joint Powers Board must use funds efficiently and effectively and in accordance with Federal OMB Uniform Guidance to prevent mismanagement of projects funded by Federal awards. Questioned Costs Less than $25,000 Recommendation We recommend that the Joint Power Board update their written internal control policies to contain all Uniform Guidance regulations, relating to Sams. gov debarment and suspension and Davis Bacon Wage Requirements. It is recommended that these be policies and internal controls be reviewed and aligned with the Federal Award contractual agreeements on a routine basis. View of Responsible Officials and Planned Corrective Actions Please see the last page of this report for the written response from the Board.