Finding 948511 (2023-004)

Significant Deficiency
Requirement
P
Questioned Costs
-
Year
2023
Accepted
2024-03-04

AI Summary

  • Core Issue: The city's written policies and procedures for procurement and conflicts of interest lack essential elements required by Uniform Guidance.
  • Impacted Requirements: Compliance with 2 CFR Part 200 is at risk due to incomplete policies, increasing the chance of noncompliance.
  • Recommended Follow-Up: The city should create comprehensive written policies for each federal program and adopt a grant management policy that aligns with Uniform Guidance.

Finding Text

WRITTEN POLICIES AND PROCEDURES / CRITERIA/ UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART D - POST FEDERAL AWARD REQUIREMENTS SECTION 200.300 THROUGH 200.346 REQUIRES THAT THE GRANTEE ESTABLISH WRITTEN POLICIES AND PROCEDURES FOR ADMINISTRATION OF THE APPLICABLE FEDERAL COMPLIANCE REQUIREMENTS. / CONDITION / THE CITY HAS APPROVED WRITTEN POLICIES AND PROCEDURES FOR PROCUREMENT AND CONFLICTS OF INTEREST. HOWEVER, THE APPROVED PROCEDURES DO NOT CONTAIN ALL THE REQUIRED ELEMENTS OF THE UNIFORM GUIDANCE. / CAUSE / THE CITY WAS NOT AWARE THAT UNIFORM GUIDANCE REQUIRED WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT / EFFECT / THE RISK OF NONCOMPLIANCE WITH AN APPLICABLE COMPLIANCE REQUIREMENT IS INCREASED WITHOUT WRITTEN POLICIES AND PROCEDURES. / QUESTIONED COSTS / THERE ARE NOT ANY QUESTIONED COSTS AS A RESULT OF THIS FINDING. / PERSPECTIVE / THE CONDITION WOULD BE CONSIDERED SYSTEMATIC, IN THAT THE CITY'S WRITTEN PROCEDURES DO NOT ADDRESS THE REQUIREMENTS OF UNIFORM GUIDANCE. / PRIOR FINDING / THE CITY DID NOT HAVE A SINGLE AUDIT IN THE PRIOR YEAR, AND THEREFORE PRIOR AUDIT FINDINGS DO NOT APPLY TO THIS MATTER. / RECOMMENDATIONS / THE CITY SHOULD REVIEW THE REQUIREMENTS OF EACH FEDERAL PROGRAM AND DEVELOP WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT. THE CITY SHOULD ADOPT A WRITTEN GRANT MANAGEMENT POLICY THAT INCORPORATES UNIFORM GUIDANCE AND IS APPLICABLE TO FEDERAL AWARDS. / MANAGEMENT RESPONSE / THE CITY AGREES WITH THE FINDING. IN SUBSEQUENT YEARS, THE CITY WILL REVIEW THE FEDERAL PROGRAMS AND DEVELOP WRITTEN POLICIES AND PROCEDURES THAT ADDRESS THE ADMINISTRATION OF EACH APPLICABLE FEDERAL COMPLIANCE REQUIREMENT IN CONFORMITY WITH UNIFORM GUIDANCE.

Categories

Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Other Findings in this Audit

  • 372064 2023-004
    Significant Deficiency
  • 372065 2023-004
    Significant Deficiency
  • 372066 2023-005
    Significant Deficiency
  • 372067 2023-004
    Significant Deficiency
  • 372068 2023-004
    Significant Deficiency
  • 372069 2023-004
    Significant Deficiency
  • 372070 2023-005
    Significant Deficiency
  • 948506 2023-004
    Significant Deficiency
  • 948507 2023-004
    Significant Deficiency
  • 948508 2023-005
    Significant Deficiency
  • 948509 2023-004
    Significant Deficiency
  • 948510 2023-004
    Significant Deficiency
  • 948512 2023-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $268,865
20.205 Highway Planning and Construction $228,527
10.766 Community Facilities Loans and Grants $127,780
21.027 Coronavirus State and Local Fiscal Recovery Funds $94,875