Finding Text
Develop Written Policies and Procedures
Criteria:
2 CFR 200.303 requires nonfederal entities to establish and maintain effective internal control over federal awards to provide reasonable assurance that organizations who manage the federal award:
• Understand and comply with the federal statutes, regulations, and terms and conditions of the award;
• Evaluate and monitor compliance;
• Take prompt action when instances of noncompliance is identified.
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).
Additionally, the Uniform Guidance requires non-federal entities to develop written procedures related to the following areas:
1. Cash Management
2 CFR 200.302(b)(6) states that the financial management system of each non-Federal entity must provide for the written procedures to implement the requirements of 2 CFR 200.305 Federal Payment.
2. Equipment Management Requirements
Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e).
In addition, the organizations should ensure that existing written procedures are in compliance with:
a. General Procurement Standards
2 CFR 200.318 to 200.327 discusses that contracts must be established and managed in accordance with the procurement requirements in 2 CFR Part 200. Grantees must have written procurement policies and procedures that demonstrate a fair and reliable process, with standards of conduct addressing conflicts of interest, for obtaining grant-funded goods and services.
Condition
MARTA does not have comprehensive written policies and procedures concerning the following key compliance areas which are required by the Uniform Guidance:
Equipment and Real Property Management
MARTA has an Asset Inventory Policy and Procedures, however, it does not clearly define the policies and procedures that are in place for the use, management and disposition of equipment acquired under a Federal award in accordance with 2 CFR sections 200.313(c) through (e).
Cash Management
MARTA does not have written procedures to implement the requirements of 2 CFR 200.305 Federal Payment.
Procurement, Suspension and Debarment
MARTA has a Procurement policy, however, documented procedures are not well-defined regarding the purchase process for different types of procurement, obtaining quotations, bidding, and procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded.
Cause
MARTA’s reliance on informal business practices leads to inconsistencies in its internal controls.
Effect
The absence of formal policies and procedures in the key compliance areas could result in non-compliance with federal regulations, which may lead to unnecessary sanctions. Additionally, without formal written policies and procedures, it is difficult to ensure consistent practices across the organization.
Questioned Costs
None
Recommendation
MARTA should develop and implement formal written policies and procedures for the specific areas required by the Uniform Guidance. These policies and procedures must clearly delineate the requirements of the Uniform Guidance. Personnel responsible for these areas should receive adequate training and apply the policies effectively. Regular reviews should be conducted to update the policies and procedures as needed.
Views of Responsible Officials and Planned Corrective Action
MARTA has grown substantially in the last several years. This progress includes identifying areas that we need to update or to develop new processes and documentation.
MARTA has an Asset Inventory Policy and Procedures in which the purpose is to ensure that fixed assets are properly accounted for, identified, and tracked.
MARTA also has Cash Handling Policy and Procedures which addresses safeguarding public funds and maximizing resources available. This is designed to reduce the risks associated with the collection, receipts storage and reporting of cash transactions and to safeguard and maintain the security and integrity of MARTA's fiscal assets.
MARTA is in the process of updating the Procurement Policy.
MARTA will review and update these policies and/or create new policies to make sure that they are compliant with the Uniform Guidance. The updated or newly created policies will be brought to the October 2025 Board of Directors meeting for Board review or approval.
Personnel responsible: Sandy Benson, General Manager
Anticipated completion date: October 2025