Finding Text
Finding 2021-006 – Noncompliance Over Major Federal Program – Activities Allowed or Unallowed
and Allowable Costs/Cost Principles-Coronavirus Relief Fund
PASS THROUGH GRANTOR: Oklahoma Office of Management and Enterprise Services
FEDERAL AGENCY: U.S. Department of Treasury
ASSISTANCE LISTING: 21.019
FEDERAL PROGRAM NAME: Coronavirus Relief Fund
FEDERAL AWARD NUMBER: SA-0161
FEDERAL AWARD YEAR: 2021
CONTROL CATEGORY: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
QUESTIONED COSTS: $59,595
Condition: After performing expenditure testwork on 100% of the program, disbursements totaling
$59,595 were not expended in accordance with the Activities Allowed or Unallowed and Allowable
Costs/Cost Principles compliance requirements due to unsubstantiated and ineligible costs. We noted the
following:
• Reimbursed payroll expenditures totaling $51,552 were previously reimbursed by another entity.
• Reimbursed payroll expenditures totaling $7,075 were previously reimbursed by another federal
grant.
• One employee’s salary totaling $569 was submitted and paid twice on two reimbursement requests.
• Expenditures totaling $399 were unaccounted for and were not supported by adequate
documentation to determine costs were incurred for allowable cost/cost principles.
Cause of Condition: Policies and procedures have not been designed and implemented to ensure
compliance with federal award requirements.
Effect of Condition: These conditions resulted in noncompliance with grant requirements. The County
runs the risk of misappropriation of funds which could hinder the County from receiving future federal
funding. Further, this condition could result in the repayment of funds.
Recommendation: OSAI recommends the County design and implement policies and procedures to ensure
compliance with applicable grant requirements.
Management Response:
Chairman of the Board of County Commissioners: We will implement policies and procedures to ensure
compliance with applicable grant requirements.
County Clerk: We will watch closer ensure compliance with applicable grant requirements.
County Treasurer: I will do my part to assist in the design and implementation of policies and procedures
to ensure compliance with applicable grant requirements.
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).
Additionally, 2 CFR § 200.403 - Factors affecting allowability costs states in part, “Except where
otherwise authorized by statute, costs must meet the following general criteria in order to
be allowable under Federal awards:
(g) Be adequately documented.”
The Department of the Treasury Federal Register, Vol. 86, No. 10 states in part, “Fund payments
may not be used for expenses that have been or will be reimbursed by another federal
program.”
Additionally, guidance provided in the Subrecipient Agreement - Federal Funding Certification
executed 6/04/2020 between Choctaw County and the State of Oklahoma states in part,
5. Funds provided as a direct payment from the State of Oklahoma pursuant to this
certification must adhere to official federal guidance issued or to be issued on what
constitutes a necessary expenditure. Any funds expended by a political subdivision or its
grantee(s) in any manner that does not adhere to official federal guidance or in violation of
this certification shall be returned to the State of Oklahoma Coronavirus Relief Fund.
6. Any local government entity receiving funds pursuant to this certification shall retain
documentation of all uses of the funds…
10. I acknowledge and certify that Recipient has not received, and will not apply for, federal
funds from any other source, to reimburse it for the expenditures for which funds are sought
pursuant hereto.