Finding Text
2024-005 – Failure to Implement Required Written Policies
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Control over Compliance (Cash Management and Allowable Costs/Cost Principles).
Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers
Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including bidding and a conflict of interest policy) (§200.318); 3) Allowability of costs charged to federal programs (§200.302 (7)); 4) Compensation (personnel and benefits policy) (§200.430 and §200.431); and 5) Travel costs (including mileage and per diem) (§200.474).
Condition. There are no written policies in place covering payments, procurement, allowability of costs charged to federal programs, compensation, or travel costs.
Cause. This condition appears to have been caused by a lack of knowledge of applicable federal compliance requirements.
Effect. As a result of this condition, the Organization did not fully comply with the Uniform Guidance.
Questioned Costs. No costs are required to be questioned as a result of this finding.
Recommendation. We recommend that written policies be put in place for all required processes to comply with requirements.
View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.