TOWN OF OWEGOState Government

(#2024-002) Policy Updates for Uniform Guidance – CFDA No. 21.027 – Coronavirus State and Local Fiscal Recovery Funds Year Ended – December 31, 2024 Direct Program Federal Agency – U.S. Department of Agriculture Criteria – the Town’s procurement policy must incorporate federal award activity within the process and procedures followed by the Town in accordance with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), sections 200.112, 200.317-200.326. Under the Uniform Guidance, the procurement requirements were required to be implemented by January 1, 2018 for federal award recipients. Condition – The Town’s code of ethics, conflict of interest and procurement policies have not been updated to comply with the requirements in the Uniform Guidance. Cause – The control environment related to the requirements of the Uniform Guidance has not be reviewed and incorporated into the Town’s control activities through the updating and documentation of the Town’s policies noted above. Effect – The Town was not in compliance with the requirements of the Uniform Guidance, Section 200.112, Conflict of Interest and Sections 200.317-200.326, Procurement Standards. Questioned Costs – There were no questioned costs noted related to this finding. Context – This finding was identified during inquiries of management in regards to the control environment over the requirements of the Uniform Guidance and through the review of the related policies noted above. Recommendation – We recommend the Town review their policies and establish/update such policies to ensure compliance with the Uniform Guidance. Town’s Response – The Town will make every effort in the future to record accruals and present the financial statements in accordance with generally accepted accounting principles.