Finding Text
PASS-THROUGH GRANTOR: Oklahoma Department of Emergency Management and Oklahoma
Office and Management and Enterprise Services
FEDERAL AGENCY: U.S. Department of Treasury
ASSISTANCE LISTING: 21.019
FEDERAL PROGRAM NAME: Coronavirus Relief Fund
FEDERAL AWARD NUMBER: Oklahoma CARES PPE; 4530-DR-OK; SA-2242
FEDERAL AWARD YEAR: 2021
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Costs Principles; and
Period of Performance
QUESTIONED COSTS: $-0-
Condition: During the process of documenting the County’s internal controls regarding federal
disbursements, we noted that Ottawa County has not established procedures to ensure compliance with the
following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/Costs Principles
and Period of Performance.
Submissions for reimbursement from the Coronavirus Relief Fund were not reviewed by the BOCC for
Activities Allowed/Allowed Costs, or to ensure the expenses were incurred during the allowable period of
performance.
Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal
expenditures are made in accordance with federal grant compliance requirements.
Effect of Condition: This condition could result in noncompliance with grant requirements and could lead
to the loss of federal funds to the County.
Recommendation: OSAI recommends the County gain an understanding of requirements for this program
and implement internal control procedures to ensure compliance with all requirements.
Management Response:
District 1 County Commissioner: Ottawa County has implemented internal control procedures to ensure
compliance with all requirements.
District 2 County Commissioner: I was not in office at this time; however, I will work to gain an
understanding of grant requirements and implement internal controls to ensure compliance with those
requirements.
District 3 County Commissioner: I did not take office until January 2023; however, District 3 will work
to better understand all requirements of federal programs and implement better procedures to follow all
guidelines to ensure compliance.
County Clerk: The County Clerk’s office is continuously learning policies and procedures needed to
ensure the County’s federal programs have adequate internal controls. The County Clerk’s office will work
on getting written internal control policies and procedures in place.
Criteria: 2 CFR § 200.303(a) Internal Controls reads as follows:
The non-Federal entity must:
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. These internal controls should be in compliance with guidance in “Standards for
Internal Control in the Federal Government” issued by the Comptroller General of the
United States or the “Internal Control Integrated Framework”, issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR § 213 states, “Non-federal entities are subject to the non-procurement debarment and
suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180.
These regulations restrict awards, subawards, and contracts with certain parties that are
debarred, suspended, or otherwise excluded from or ineligible for participation in Federal
assistance programs or activities.”
Additionally, GAO Standards – Section 2 – Establishing an Effective Internal Control System – OV2.23
states in part:
Objectives of an Entity – Compliance Objectives
Management conducts activities in accordance with applicable laws and regulations. As
part of specifying compliance objectives, the entity determines which laws and regulations
apply to the entity. Management is expected to set objectives that incorporate these
requirements.