Finding Text
riteria:The Uniform Guidance requires grantees to design and implement formalized internal control policies and procedures which address the compliance requirements associated with all federal programs administered by the grantee. Condition and context: The County has worked with other counties and third parties in the establishment of procedures, and electronic portals to streamline the administration of the program. The County enters into a written agreement with each community identifying the community as a subrecipient of the County. Additionally, the County has contracted with two third-party consultants to assist in the initial examination of eligibility of submitted applications in accordance with US Treasury’s program guidelines and additional compliance requirement monitoring. Final approval is performed by the County. Moreover, as reported in the prior year (fiscal year 2022), policies and procedures which more clearly detail and document the processes (subrecipient monitoring) were not yet fully designed and implemented for fiscal year 2023. Per our current year audit, and discussions with personnel, we noted the County implemented additional subrecipient monitoring during fiscal year 2024 for the quarter ending June 30, 2023. A subrecipient monitoring report and associated follow-up procedures was issued by the consultant December 28, 2023. The County indicates it is working to ensure subrecipient monitoring is performed timely. During the current year audit, we also noted the certain activity reported in the County’s required Annual Performance Report surrounding the program for the fiscal year ending June 30, 2023, could not be reconciled with the initial underlying tracking spreadsheets and information provided. We recommend personnel maintain documentation at the time of reporting to ensure accuracy and reconciliation to underlying documentation. During our testing of certain applications submitted during the fiscal year, we noted one instance in which a subrecipient grant agreement which was not signed by the County. We noted all payments made during fiscal year 2023 associated with the program were approved by the County Commissioners. In our professional opinion personnel should ensure all approvals are documented through established procedures. Moreover, steps should be taken to ensure annual reporting is supported by underlying documentation at the time of the reporting. Cause:Due to the nature of the award, initial incomplete and changing guidance related thereto, the County worked to provide the fiscal relief to communities in a timely manner. Accordingly, all aspects of the program administration required continued review and implementation. Effect or potential effect: Noncompliance could occur. Questioned costs: None. Auditor’s recommendation: In our professional judgement, we recommend the County continue to evaluate (and more formally document) internal control policies and procedures (inclusive of responsibilities, duties, documentation related thereto) associated with overall administration (and subrecipient monitoring) of the program. In our opinion this should more clearly define parameters of the results of the risk assessment process and the depth of subrecipient monitoring, and County decisions related thereto. We recommend the County review and update current policies and procedures manuals to ensure all of the County’s federal programs’ internal control over compliance and central monitoring and reporting thereof is being met. Views of responsible officials: The County has developed a formalized internal control policy and procedures, including a robust subrecipient monitoring program. The procedures include control environment, risk assessment, control activities, and information and communication monitoring. As part of the procedure, the County ensures that all documentation associated with subrecipient grants are maintained by the County. As indicated, the County has implemented current subrecipient policies and procedures.