Finding Text
2024-004: Written Policies Required by the Uniform Guidance
Finding Type: Material Weakness in Internal Controls and Noncompliance (Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Reporting)
Federal Program: U.S. Department of Treasury – Local Assistance and Tribal Consistency Fund (AL #21.032)
Criteria: The County does not have written policies and procedures to implement the requirements of 2 CFR section 200 for the administration of federal awards. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant on or after December 26, 2014 to have written policies pertaining to: 1) advance payments and reimbursements (financial management); 2) determination of allowable costs; 3) compensation (personnel and benefits policies); 4) travel costs; and 5) procurement procedures. 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal controls over the federal awards that provide assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the conditions of the federal award.
Condition: The County does not have processes or written policies in place to conform to all of the requirements in the Uniform Guidance.
Cause: The County has not reviewed and updated its policies and procedures for continued changes in grants and the Uniform Guidance.
Effect: As a result of this condition, the County did not fully comply with the Uniform Guidance.
Questioned Costs: No costs have been questioned as a result of this finding.
Recommendation: We recommend that the County adopt formal written policies covering these areas as soon as practical.
Views of Responsible Officials: The County will work to update policies and procedures and to formalize responsibilities.