Finding 565795 (2020-012)

Material Weakness Repeat Finding
Requirement
ABGHILN
Questioned Costs
-
Year
2020
Accepted
2025-06-23

AI Summary

  • Core Issue: The County lacks a designed internal control system for federal grants, risking noncompliance and potential loss of federal funds.
  • Impacted Requirements: Key areas affected include Control Environment, Risk Assessment, Information and Communication, and Monitoring as per federal guidelines.
  • Recommended Follow-up: The County should develop and implement comprehensive internal controls to ensure compliance with grant requirements and effective management of federal awards.

Finding Text

PASS THROUGH GRANTOR: Direct Grant; Oklahoma Department of Transportation FEDERAL AGENCY: U.S. Department of Commerce; U.S. Department of Transportation ASSISTANCE LISTING: 11.300 and 20.205 FEDERAL PROGRAM NAME: Investment for Public Works and Economic Development Facilities and Highway Planning and Construction FEDERAL AWARD NUMBER: ERSTP 262C(075), ERSTP 266C(076), ERSTP 266C(077), and ERSTP 266C (082)) FEDERAL AWARD YEAR: 2020 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Costs Principles; Matching; Period of Performance, Procurement and Suspension and Debarment, Reporting; and Special Tests and Provisions. QUESTIONED COSTS: $-0- Condition: Through the process of gaining an understanding of the County’s internal control structure for federal programs, it was noted that county-wide internal controls regarding Control Environment, Risk Assessment, Information and Communication, and Monitoring have not been designed. Cause of Condition: Policies and procedures have not been designed and implemented to ensure the County complies with grant requirements. Effect of Condition: This condition could result in noncompliance to grant requirements and loss of federal funds. Recommendation: OSAI recommends that the County design and implement a system of internal controls to ensure compliance with grant requirements. Management Response: Board of County Commissioners: The BOCC is responsible for the overall fiscal concerns of the county. See OKLA. STAT. Title 19, § 345. The BOCC, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The BOCC will work with all elected officials and with the state and local partners in each federal award to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. These policies and procedures will be designed to identify requirements for recipients and sub-recipients of grants, ensure accurate equipment and real property management, procurement, recipient and subrecipient monitoring and reporting. Further, policies will ensure a proper understanding of all grant requirements and compliance of the same. Criteria: The GAO Standards – Section 1 – Fundamental Concepts of Internal Control – OV1.01 states in part: Definition of Internal Control Internal control is a process effected by an entity’s oversight body, management, and other personnel that provides reasonable assurance that the objectives of an entity will be achieved. Additionally, GAO Standards – Section 2 – Establishing an Effective Internal Control System – OV2.04 states in part: Components, Principles, and Attributes Control Environment - The foundation for an internal control system. It provides the discipline and structure to help an entity achieve its objectives. Risk Assessment - Assesses the risks facing the entity as it seeks to achieve its objectives. This assessment provides the basis for developing appropriate risk responses. Information and Communication - The quality information management and personnel communicate and use to support the internal control system. Monitoring - Activities management establishes and operates to assess the quality of performance over time and promptly resolve the findings of audits and other reviews. Furthermore, 2 CFR § 200.303 Internal Controls (a) 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).

Categories

Subrecipient Monitoring Procurement, Suspension & Debarment Internal Control / Segregation of Duties Equipment & Real Property Management Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 565792 2020-008
    Material Weakness Repeat
  • 565793 2020-012
    Material Weakness Repeat
  • 565794 2020-008
    Material Weakness Repeat
  • 1142234 2020-008
    Material Weakness Repeat
  • 1142235 2020-012
    Material Weakness Repeat
  • 1142236 2020-008
    Material Weakness Repeat
  • 1142237 2020-012
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
20.205 Highway Planning and Construction $331,220
11.300 Investments for Public Works and Economic Development Facilities $306,603
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $167,716
15.226 Payments in Lieu of Taxes $90,605
20.600 State and Community Highway Safety $74,552
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $46,698
12.106 Flood Control Projects $31,823
97.042 Emergency Management Performance Grants $23,551
21.016 Equitable Sharing $20,785
16.607 Bulletproof Vest Partnership Program $7,480
97.073 State Homeland Security Program (shsp) $5,744
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $960