Finding Text
2024-005 (2023-008) – INADEQUATE POLICIES AND PROCEDURES UNDER UNIFORM GUIDANCE
Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards
Funding Agency: All (see Schedule of Expenditures of Federal Awards)
Title: All (see Schedule of Expenditures of Federal Awards)
AL #: All (see Schedule of Expenditures of Federal Awards)
Award #: All (see Schedule of Expenditures of Federal Awards)
Award Period: All (see Schedule of Expenditures of Federal Awards)
Questioned Costs: None
Statement of Condition
The County does not have written policies and procedures in place addressing key requirements under 2 CFR 200 (Uniform Guidance), specifically those required in Subparts D and E.
Management’s Progress Toward Prior Year Corrective Action Plan:
No progress has been made toward resolving this finding as of June 30, 2024.
Criteria
Uniform Guidance (2 CFR Part 200) mandates documented procedures in several critical areas of federal program management, including cash management, allowable costs, procurement, and conflict of interest:
Cash Management (2 CFR §200.302(b)(6)):
Requires written procedures detailing how the County manages cash flows for federal programs. Procedures should clearly define responsibilities for monitoring cash transactions, the timing of cash drawdowns, reimbursement claims, obligations, and the verification steps taken to ensure compliance.
Allowable Costs (2 CFR §200.302(b)(7)):
Requires written procedures specifying how allowable costs are determined, documented, reviewed, and claimed under each federal program in compliance with the Uniform Guidance cost principles.
Procurement (2 CFR §200.318(a)):
Requires documented procurement policies that adhere to federal standards as well as applicable State, local, and tribal laws. These procedures must clearly outline steps for soliciting, evaluating, awarding, and documenting procurements using federal funds.
Cause
The County has not developed or implemented written policies and procedures to address the federal program financial management requirements under the Uniform Guidance.
Effect
The absence of required written procedures places the County at risk of noncompliance with Uniform Guidance, potentially resulting in sanctions, disallowed expenditures, repayment obligations, or loss of future federal funding.
Recommendation
The County should promptly develop and adopt comprehensive written procedures addressing cash management, allowable costs, procurement, and conflict of interest. Once approved, these procedures should be distributed and communicated clearly to all relevant personnel managing or overseeing federal programs.