Finding Text
2024-003 – Written Policies Required by the Uniform Grant Guidance
Finding Type. Significant Deficiency in Internal Control over Compliance and Immaterial Noncompliance
(Procurement and Suspension and Debarment)
Program. COVID-19 State and Local Fiscal Recovery Funds Cluster (CFDA# 21.027); U.S. Department of
Treasury; Passed through Lake County.
Criteria. Non-federal entities other than states, including those operating federal programs as subrecipients
of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They
must use their own documented procurement procedures, which reflect applicable state and local laws and
regulations, provided that the procurements conform to applicable federal statutes and the procurement
requirements identified in 2 CFR Part 200.
Condition. The District did not have documented procurement standards to comply with 2 CFR sections
200.318 through 200.326.
Cause. The District has drafted a policy for these areas in accordance with 2 CFR Part 200, but it has not
been finalized.
Effect. As a result of this condition, the District did not fully comply with 2 CFR Part 200 applicable to the
above noted grant.
Questioned Costs. No costs have been questioned as a result of this finding.
Recommendation. We recommend that the District develop a policy as soon as practical, but no later than
the end of fiscal year 2025, to comply with 2 CFR sections 200.318 through 200.326.
View of Responsible Officials. We agree with the recommendation and will develop procedures to comply
with the Uniform Guidance applicable to grants
Repeat finding. 2023-003