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Yolo County Transportation DistrictLocal Government

EIN: 320262241

UEI: L2GTUNHW81V1

Audited by: Richardson & Company, LLP

Oversight agency: 20 [Department of Transportation]

View federal awards & risk assessment →

Data as of September 2, 2026

Yolo County Transportation District10 audit years7 findings4 repeat
10
Audit Years
7
Total Findings
4
Repeat Findings
$8.1M
Federal Awards Expended (FY 2025)

FY 2025-06-30

MATERIAL NONCOMPLIANCE DISCLOSED$8,133,832 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on April 29, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by October 29, 2026 (54 days from today).

What is a management decision? →
2025-002
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2024-003OTHER MATTERS

Several changes were made to the schedule of expenditures of federal awards (SEFA) after the single audit began, including: • The periods of performance had to be updated on several grants. • Missing criteria, such as the award date, had to be added for new grants. • The assistance listing number was corrected for two grants. • A grant amount immaterial to the major program was removed from the SEFA after the single audit began. • Adjustments were made to the SEFA after the audit began to claim current year expenses for disallowed 2024 costs to fully implement the recommendation made in the 2024 single audit. • Qualified expenses were shifted between eligible routes for one grant on the SEFA. Criteria: 2 CFR Part 200, Subpart E (Uniform Guidance) Section 200.303 states that “The nonfederal entity must: (a) 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.” Cause:. Grant management procedures are not documented, a complete schedule of all available grants to use when reconciling expenses for inclusion on the SEFA and accruing grant revenue was a work in progress and not all necessary changes were identified by the District’s review procedures Effect: Expenses were omitted from the SEFA and other expenses were included on the SEFA that were already reported in the prior year. The SEFA had to be revised, which delayed the audit testing and major program determination process. Context: The number of grants has increased since the pandemic due to new pandemic related grants becoming available that delayed the use of the District’s regular federal grants. This caused grants to be combined by grantors with different allowable expenses, areas of service, and periods of performance and caused grants to be extended, causing significant complexity. The dollar amount of auditor changes made to the SEFA were immaterial and the SEFA was not relied upon by the District to ensure compliance with compliance requirements so the changes to the SEFA did not result in noncompliance with other compliance requirements. The District staff made a significant effort to bill all qualifying expenses during the audit, which will help reduce the complexity of remaining grants in future years. Recommendation: We recommend the District develop written procedures to allocate expenses to routes and purposes under federal grants that document the timing of the preparation and review of the allocation schedule. A summary tab should be added to the allocation schedule to reconcile amounts for each route/purpose to total operating expenses, preventive maintenance, insurance, communications and other expenses allocated to the population of expenses in the general ledger. We also recommend the District develop a schedule to summarize all approved and pending grants that includes the amounts available under each grant, each route/purpose within each grant, periods of performance for each amount available, the last date to submit invoices, and amounts claimed and still available for each grant by route/purpose. The District should re-evaluate budgets if changes or delays occur to federal grants and ensure a new federal or local funding source is identified and claimed for the expenses. The SEFA should be prepared after expenses are reconciled to the general ledger at the invoice/paycheck level by route/purpose and the allocation schedule is thoroughly reviewed. The SEFA should be reviewed by a knowledgeable member of management to ensure completeness and accuracy. We also recommend the District claim expenses more quickly to allow the granting agency time to review and approve the claims before the audit begins. We recommend the District reconcile expenses within 30 days of quarter end and prepare claims within 45 days of quarter end. If the District is unsure about the period of performance dates or other restrictions on a grant, staff should contact the granting agency for clarification. Finally, we recommend the District request the grants be made available for general operating expenses rather than for individual routes, times etc. to reduce complexity wherever possible. View of Responsible Officials and Planned Corrective Action: Management’s response and planned corrective action is included at the Corrective Action Plan end of this report.

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Full finding narrative

2025-002 – Significant Deficiency AL Nos: 20.507 and 20.526, 20.205 Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Cluster - Direct Award Compliance Requirement: Other Compliance Requirements Award Nos: All awards under Assistance Listing (AL) Numbers 20.507, 20.526, and 20.205 Condition: Several changes were made to the schedule of expenditures of federal awards (SEFA) after the single audit began, including: • The periods of performance had to be updated on several grants. • Missing criteria, such as the award date, had to be added for new grants. • The assistance listing number was corrected for two grants. • A grant amount immaterial to the major program was removed from the SEFA after the single audit began. • Adjustments were made to the SEFA after the audit began to claim current year expenses for disallowed 2024 costs to fully implement the recommendation made in the 2024 single audit. • Qualified expenses were shifted between eligible routes for one grant on the SEFA. Criteria: 2 CFR Part 200, Subpart E (Uniform Guidance) Section 200.303 states that “The nonfederal entity must: (a) 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.” Cause:. Grant management procedures are not documented, a complete schedule of all available grants to use when reconciling expenses for inclusion on the SEFA and accruing grant revenue was a work in progress and not all necessary changes were identified by the District’s review procedures Effect: Expenses were omitted from the SEFA and other expenses were included on the SEFA that were already reported in the prior year. The SEFA had to be revised, which delayed the audit testing and major program determination process. Context: The number of grants has increased since the pandemic due to new pandemic related grants becoming available that delayed the use of the District’s regular federal grants. This caused grants to be combined by grantors with different allowable expenses, areas of service, and periods of performance and caused grants to be extended, causing significant complexity. The dollar amount of auditor changes made to the SEFA were immaterial and the SEFA was not relied upon by the District to ensure compliance with compliance requirements so the changes to the SEFA did not result in noncompliance with other compliance requirements. The District staff made a significant effort to bill all qualifying expenses during the audit, which will help reduce the complexity of remaining grants in future years. Recommendation: We recommend the District develop written procedures to allocate expenses to routes and purposes under federal grants that document the timing of the preparation and review of the allocation schedule. A summary tab should be added to the allocation schedule to reconcile amounts for each route/purpose to total operating expenses, preventive maintenance, insurance, communications and other expenses allocated to the population of expenses in the general ledger. We also recommend the District develop a schedule to summarize all approved and pending grants that includes the amounts available under each grant, each route/purpose within each grant, periods of performance for each amount available, the last date to submit invoices, and amounts claimed and still available for each grant by route/purpose. The District should re-evaluate budgets if changes or delays occur to federal grants and ensure a new federal or local funding source is identified and claimed for the expenses. The SEFA should be prepared after expenses are reconciled to the general ledger at the invoice/paycheck level by route/purpose and the allocation schedule is thoroughly reviewed. The SEFA should be reviewed by a knowledgeable member of management to ensure completeness and accuracy. We also recommend the District claim expenses more quickly to allow the granting agency time to review and approve the claims before the audit begins. We recommend the District reconcile expenses within 30 days of quarter end and prepare claims within 45 days of quarter end. If the District is unsure about the period of performance dates or other restrictions on a grant, staff should contact the granting agency for clarification. Finally, we recommend the District request the grants be made available for general operating expenses rather than for individual routes, times etc. to reduce complexity wherever possible. View of Responsible Officials and Planned Corrective Action: Management’s response and planned corrective action is included at the Corrective Action Plan end of this report.

Corrective Action Plan

Finding 2025-002 – Significant Deficiency AL Nos: 20.507 and 20.526, 20.205 Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Cluster - Direct Award Compliance Requirement: Other Compliance Requirements Award Nos: All awards under Assistance Listing (AL) Numbers 20.507, 20.526, and 20.205 Condition: Several changes were made to the schedule of expenditures of federal awards (SEFA) after the single audit began, including: - The periods of performance had to be updated on several grants. - Missing criteria, such as the award date, had to be added for new grants. - The assistance listing number was corrected for two grants. - A grant amount immaterial to the major program was removed from the SEFA after the single audit began. - Adjustments were made to the SEFA after the audit began to claim current year expenses for disallowed 2024 costs to fully implement the recommendation made in the 2024 single audit. - Qualified expenses were shifted between eligible routes for one grant on the SEFA. Criteria: 2 CFR Part 200, Subpart E (Uniform Guidance) Section 200.303 states that “The nonfederal entity must: (a) 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.” Cause: Grant management procedures are not documented, a complete schedule of all available grants to use when reconciling expenses for inclusion on the SEFA and accruing grant revenue was a work in progress and not all necessary changes were identified by the District’s review procedures. Effect: Expenses were omitted from the SEFA and other expenses were included on the SEFA that were already reported in the prior year. The SEFA had to be revised, which delayed the audit testing and major program determination process. Context: The number of grants has increased since the pandemic due to new pandemic related grants becoming available that delayed the use of the District’s regular federal grants. This caused grants to be combined by grantors with different allowable expenses, areas of service, and periods of performance and caused grants to be extended, causing significant complexity. The dollar amount of auditor changes made to the SEFA were immaterial and the SEFA was not relied upon by the District to ensure compliance with compliance requirements so the changes to the SEFA did not result in noncompliance with other compliance requirements. The District staff made a significant effort to bill all qualifying expenses during the audit, which will help reduce the complexity of remaining grants in future years. Recommendation: We recommend the District develop written procedures to allocate expenses to routes and purposes under federal grants that document the timing of the preparation and review of the allocation schedule. A summary tab should be added to the allocation schedule to reconcile amounts for each route/purpose to total operating expenses, preventive maintenance, insurance, communications and other expenses allocated to the population of expenses in the general ledger. We also recommend the District develop a schedule to summarize all approved and pending grants that includes the amounts available under each grant, each route/purpose within each grant, periods of performance for each amount available, the last date to submit invoices, and amounts claimed and still available for each grant by route/purpose. The District should re-evaluate budgets if changes or delays occur to federal grants and ensure a new federal or local funding source is identified and claimed for the expenses. The SEFA should be prepared after expenses are reconciled to the general ledger at the invoice/paycheck level by route/purpose and the allocation schedule is thoroughly reviewed. The SEFA should be reviewed by a knowledgeable member of management to ensure completeness and accuracy. We also recommend the District claim expenses more quickly to allow the granting agency time to review and approve the claims before the audit begins. We recommend the District reconcile expenses within 30 days of quarter end and prepare claims within 45 days of quarter end. If the District is unsure about the period of performance dates or other restrictions on a grant, staff should contact the granting agency for clarification. Finally, we recommend the District request the grants be made available for general operating expenses rather than for individual routes, times etc. to reduce complexity wherever possible. 2025-002 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the recommendation and recognizes the importance of maintaining strong procedures for the monitoring, allocation and claiming of federal grant expenses. Over the past year, the District has made significant progress addressing the complexity created by the increase in federal grants following the pandemic, including reviewing prior year grant activity, resolving overclaims, coordinating closely with Federal Transit Administration (FTA), and amending grants where necessary. During this process, the District delayed certain claims while prior year matters were being resolved to ensure that expenses were claimed appropriately and in accordance with grant requirements. Staff also developed improved internal worksheets and summary schedules to track grant activity and allocations across funding sources. As the District moves beyond the review and resolution of older grant issues, management expects continued improvement in the monitoring, management, and reconciliation of federal funding sources. The District will continue strengthening internal procedures, including developing more formal written documentation of allocation methodologies, reconciliation schedules, and review procedures. These efforts are expected to further improve timeliness, accuracy, and oversight of grant reporting and claiming activities. Responsible Party: Director of Finance & Administration Implementation Date: Ongoing; full implementation expected by December 31, 2026 YCTD Contact Person Responsible for the Correction Actions; Chas Ann Fadrigo.

Prior Finding References

2024-003

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →

FY 2024-06-30

MATERIAL NONCOMPLIANCE DISCLOSED$6,928,489 federal awards expended

FAC accepted this audit on March 28, 2025 — management decision was due September 28, 2025.

2024-003
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2023-003QUESTIONED COSTS

The District’s internal controls over compliance requirements did not identify ineligible costs applied to two separate Federal Transit Administration (FTA) grants as follows.  Section 5307 Grant Award CA-2020-173-01: The District overclaimed Sacramento fixed route operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in ineligible costs of $183,848 being charged to the program. Questioned Costs: $183,548  Section 5307 Grant Award CA-2023-122-01: The District overclaimed Woodland fixed route operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in ineligible costs of $175,143 being charged to the program. Questioned Costs: $175,143. In addition to these ineligible costs, there were substantial changes to the Schedule of Expenditures of Federal Awards (SEFA) and federal grant revenue reported in the general ledger (GL) during the course of the audit. These changes and issues are as follows.  There was a total of $302,813 removed from the SEFA and GL for claims prepared for expenses incurred after the period of performance end date specified in the grant for the relevant project and therefore would have been ineligible if the claim was submitted to the grantor. These claims were prepared for paratransit and microtransit operating assistance.  There was a total of $243,823 removed from the SEFA and GL for claims prepared for an FTA direct program grant that is already past the end date of the period of performance and therefore would have been ineligible if the claim was submitted to the grantor. These claims were drafted for Woodland microtransit operating assistance.  There was a total of $354,429 added to the SEFA for federal grant revenues recorded in the GL but not initially included on the SEFA. These claims are for the Yolo County Bike and Pedestrian Trail Network Planning Project and the Yolo 80 Managed Lanes Tolling Advance Planning project.  There was a total of $1,106,389 of expenses reported on the SEFA but not recognized as revenue in the GL for amounts previously overclaimed for ineligible expenses but reclaimed and approved for eligible expenses in the current period. Criteria: 2 CFR Part 200, Subpart E (Uniform Guidance) Section 200.303 states that “The nonfederal entity must: (a) 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.” Cause:. Grant management procedures are not documented and a schedule of all available grants was not prepared by the District to use when reconciling expenses for inclusion on the SEFA and accruing grant revenue. The errors on the SEFA were not captured by the District’s review procedures due to recent staff turnover, lack of documented procedures on grant management, and/or lack of training. Effect: Expenses were omitted from the SEFA that should have been included and other expenses were included on the SEFA that were not eligible. The SEFA had to be revised for multiple grants over the course of the audit, which delayed the audit testing and major program determination process. Context: The number of grants has increased since the pandemic due to new pandemic related grants becoming available that delayed the use of the District’s regular federal grants. This caused grants to be combined by grantors with different allowable expenses, areas of service, and periods of performance and caused grants to be extended, causing complexity. The District confirmed that there will be no other federal grants used for reimbursement of the expenses that were removed from the SEFA during the audit. Recommendation: We recommend the District develop written procedures to allocate expenses to routes and purposes under federal grants that document the timing of the preparation and review of the allocation schedule. A summary tab should be added to the allocation schedule to reconcile amounts for each route/purpose to total operating expenses, preventive maintenance, insurance, communications and other expenses allocated to the population of expenses in the general ledger. We also recommend the District develop a schedule to summarize all approved and pending grants that includes the amounts available under each grant, each route/purpose within each grant, periods of performance for each amount available, the last date to submit invoices, and amounts claimed and still available for each grant by route/purpose. The District should re-evaluate budgets if changes or delays occur to federal grants and ensure a new federal or local funding source is identified and claimed for the expenses. The SEFA should be prepared after expenses are reconciled to the GL at the invoice level by route/purpose and the allocation schedule is thoroughly reviewed. The SEFA should be reviewed by a knowledgeable member of management to ensure completeness and accuracy. We also recommend the District claim expenses more quickly to allow the granting agency time to review and approve the claims before the audit begins. We recommend the District reconcile expenses within 30 days of quarter end and prepare claims within 45 days of quarter end. If the District is unsure about the period of performance dates or other restrictions on a grant, staff should contact the granting agency for clarification. Finally, we recommend the District discuss the overclaimed amounts of $183,548 and $175,143 described above with the FTA to determine whether these overclaimed funds must be returned or whether they may be used to claim future expenses. View of Responsible Officials and Planned Corrective Action: Management’s response and planned corrective action is included at the Corrective Action Plan end of this report.

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Full finding narrative

AL No: 20.507 Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Cluster - Direct Award Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles. Condition: The District’s internal controls over compliance requirements did not identify ineligible costs applied to two separate Federal Transit Administration (FTA) grants as follows.  Section 5307 Grant Award CA-2020-173-01: The District overclaimed Sacramento fixed route operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in ineligible costs of $183,848 being charged to the program. Questioned Costs: $183,548  Section 5307 Grant Award CA-2023-122-01: The District overclaimed Woodland fixed route operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in ineligible costs of $175,143 being charged to the program. Questioned Costs: $175,143. In addition to these ineligible costs, there were substantial changes to the Schedule of Expenditures of Federal Awards (SEFA) and federal grant revenue reported in the general ledger (GL) during the course of the audit. These changes and issues are as follows.  There was a total of $302,813 removed from the SEFA and GL for claims prepared for expenses incurred after the period of performance end date specified in the grant for the relevant project and therefore would have been ineligible if the claim was submitted to the grantor. These claims were prepared for paratransit and microtransit operating assistance.  There was a total of $243,823 removed from the SEFA and GL for claims prepared for an FTA direct program grant that is already past the end date of the period of performance and therefore would have been ineligible if the claim was submitted to the grantor. These claims were drafted for Woodland microtransit operating assistance.  There was a total of $354,429 added to the SEFA for federal grant revenues recorded in the GL but not initially included on the SEFA. These claims are for the Yolo County Bike and Pedestrian Trail Network Planning Project and the Yolo 80 Managed Lanes Tolling Advance Planning project.  There was a total of $1,106,389 of expenses reported on the SEFA but not recognized as revenue in the GL for amounts previously overclaimed for ineligible expenses but reclaimed and approved for eligible expenses in the current period. Criteria: 2 CFR Part 200, Subpart E (Uniform Guidance) Section 200.303 states that “The nonfederal entity must: (a) 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.” Cause:. Grant management procedures are not documented and a schedule of all available grants was not prepared by the District to use when reconciling expenses for inclusion on the SEFA and accruing grant revenue. The errors on the SEFA were not captured by the District’s review procedures due to recent staff turnover, lack of documented procedures on grant management, and/or lack of training. Effect: Expenses were omitted from the SEFA that should have been included and other expenses were included on the SEFA that were not eligible. The SEFA had to be revised for multiple grants over the course of the audit, which delayed the audit testing and major program determination process. Context: The number of grants has increased since the pandemic due to new pandemic related grants becoming available that delayed the use of the District’s regular federal grants. This caused grants to be combined by grantors with different allowable expenses, areas of service, and periods of performance and caused grants to be extended, causing complexity. The District confirmed that there will be no other federal grants used for reimbursement of the expenses that were removed from the SEFA during the audit. Recommendation: We recommend the District develop written procedures to allocate expenses to routes and purposes under federal grants that document the timing of the preparation and review of the allocation schedule. A summary tab should be added to the allocation schedule to reconcile amounts for each route/purpose to total operating expenses, preventive maintenance, insurance, communications and other expenses allocated to the population of expenses in the general ledger. We also recommend the District develop a schedule to summarize all approved and pending grants that includes the amounts available under each grant, each route/purpose within each grant, periods of performance for each amount available, the last date to submit invoices, and amounts claimed and still available for each grant by route/purpose. The District should re-evaluate budgets if changes or delays occur to federal grants and ensure a new federal or local funding source is identified and claimed for the expenses. The SEFA should be prepared after expenses are reconciled to the GL at the invoice level by route/purpose and the allocation schedule is thoroughly reviewed. The SEFA should be reviewed by a knowledgeable member of management to ensure completeness and accuracy. We also recommend the District claim expenses more quickly to allow the granting agency time to review and approve the claims before the audit begins. We recommend the District reconcile expenses within 30 days of quarter end and prepare claims within 45 days of quarter end. If the District is unsure about the period of performance dates or other restrictions on a grant, staff should contact the granting agency for clarification. Finally, we recommend the District discuss the overclaimed amounts of $183,548 and $175,143 described above with the FTA to determine whether these overclaimed funds must be returned or whether they may be used to claim future expenses. View of Responsible Officials and Planned Corrective Action: Management’s response and planned corrective action is included at the Corrective Action Plan end of this report.

Corrective Action Plan

2024-003 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the audit recommendations and remains committed to strengthening grant management and financial oversight. This year’s challenges in grant reconciliation stemmed from overlapping prior-year FTA claims issues, pending grant amendments, and limited time, as noted in Finding 2024-002. Additionally, the increased complexity of federal grants following the pandemic required adjustments to allocation methods and financial reporting. To address these issues, staff has refined internal processes, including improving worksheets, enhancing review procedures, and consolidating grant data into a single summary sheet for better tracking. The 2024 FTA Triennial Review acknowledged these improvements, and the corrective action plan was considered sufficient, with recommendations to closely monitor grant activity and update the worksheets as necessary. Moving forward, staff will continue formalizing procedures for expense allocation, improve reconciliation processes, and ensure grant expenditures align with available funding. Grant tracking will provide a clearer overview of balances, deadlines, and remaining funds. The Finance department also adjusted its billing practices to reconcile expenses earlier in the reporting cycle, allowing sufficient time for review and claim adjustments. Regarding the overclaimed amounts of $183,548 and $175,143, staff will work with the FTA to determine whether repayment is required or if the funds can be applied to future eligible expenses. These efforts will strengthen compliance, improve accuracy in financial reporting, and overall grant management. Responsible Party: Director of Finance & Administration Implementation Date: Ongoing; full implementation expected by December 31, 2025

Prior Finding References

2023-003

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2024-004
Procurement & Suspension/Debarment
MODIFIED OPINIONSIGNIFICANT DEFICIENCYREPEAT OF 2023-004

The District was unable to provide documentation of the evaluation each proposal received and reason for selection of the winning bid for the procurement of a consulting firm to conduct the site selection study for the Woodland Transit Center project. The District also did not include a Debarment and Suspension clause in the request for proposal or contract and did not require a certificate confirming the contractor was not debarred in the final agreement. The District was not able to find records of the District verifying that the awarded consulting firm is not on the governmentwide exclusions in the System for Award Management (SAM). Criteria: 2 CFR Part 200 Subpart E (Uniform Guidance) states the following:  Section 200.318(a) states that “The non-federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or service required under a Federal award or subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in Sections 200.317 through 200.327.”  Section 200.318(i) states that “The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.”  Section 200.327 states that “The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II of this part.” Appendix II(H) includes “Debarment and Suspension (Executive Orders 12549 and 12689)—A contract award (see 2 CFR 180.220) must not be made to parties listed on the governmentwide exclusions in the System for Award Management (SAM), in accordance with the OMB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR part 1986 Comp., p. 189) and 12689 (3 CFR part 1989 Comp., p. 235), “Debarment and Suspension.” SAM Exclusions contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549.” Cause: The current staff was not able to find procurement documentation prepared before they were hired. Effect: The District was unable to provide evidence that it was in compliance with the Uniform Guidance requirement to maintain documentation of procurement procedures. Context: The original procurement for the consulting firm for the Woodland Transit Project was performed in late December 2017 and awarded in January 2018 and then extended during 2024. This procurement precedes the current staff. It was verified the contractor selected was not debarred during the 2024 single audit. Recommendation: We recommend the District establish a procurement folder on its server with subfolders for each individual procurement where documentation of each procurement is maintained, including advertising of the procurement, requests for proposals, proposals received, analysis of reasons for selecting the winning bid, executed contract, certifications by contractor if not part of the proposal or executed contract, management report to board recommending which bid should be approved, board resolution approving the winning bid and for contracts under $250,000 a memo or form documenting bids received and reason for selecting the bid, including reasons for not selecting the lowest bid if applicable. We also recommend training be provided to staff that work on procurements of the requirements under Uniform Guidance Section 2 CFR 200.318 to 200.326. View of Responsible Officials and Planned Corrective Action: Management’s response and planned corrective action is included at the Corrective Action Plan end of this report.

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Full finding narrative

AL No: 20.507 Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Cluster - Direct Award. Compliance Requirement: Procurement, Suspension and Debarment. Condition: The District was unable to provide documentation of the evaluation each proposal received and reason for selection of the winning bid for the procurement of a consulting firm to conduct the site selection study for the Woodland Transit Center project. The District also did not include a Debarment and Suspension clause in the request for proposal or contract and did not require a certificate confirming the contractor was not debarred in the final agreement. The District was not able to find records of the District verifying that the awarded consulting firm is not on the governmentwide exclusions in the System for Award Management (SAM). Criteria: 2 CFR Part 200 Subpart E (Uniform Guidance) states the following:  Section 200.318(a) states that “The non-federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or service required under a Federal award or subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in Sections 200.317 through 200.327.”  Section 200.318(i) states that “The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.”  Section 200.327 states that “The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II of this part.” Appendix II(H) includes “Debarment and Suspension (Executive Orders 12549 and 12689)—A contract award (see 2 CFR 180.220) must not be made to parties listed on the governmentwide exclusions in the System for Award Management (SAM), in accordance with the OMB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR part 1986 Comp., p. 189) and 12689 (3 CFR part 1989 Comp., p. 235), “Debarment and Suspension.” SAM Exclusions contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549.” Cause: The current staff was not able to find procurement documentation prepared before they were hired. Effect: The District was unable to provide evidence that it was in compliance with the Uniform Guidance requirement to maintain documentation of procurement procedures. Context: The original procurement for the consulting firm for the Woodland Transit Project was performed in late December 2017 and awarded in January 2018 and then extended during 2024. This procurement precedes the current staff. It was verified the contractor selected was not debarred during the 2024 single audit. Recommendation: We recommend the District establish a procurement folder on its server with subfolders for each individual procurement where documentation of each procurement is maintained, including advertising of the procurement, requests for proposals, proposals received, analysis of reasons for selecting the winning bid, executed contract, certifications by contractor if not part of the proposal or executed contract, management report to board recommending which bid should be approved, board resolution approving the winning bid and for contracts under $250,000 a memo or form documenting bids received and reason for selecting the bid, including reasons for not selecting the lowest bid if applicable. We also recommend training be provided to staff that work on procurements of the requirements under Uniform Guidance Section 2 CFR 200.318 to 200.326. View of Responsible Officials and Planned Corrective Action: Management’s response and planned corrective action is included at the Corrective Action Plan end of this report.

Corrective Action Plan

2024-004 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the recommendation and has implemented measures to improve procurement recordkeeping and compliance. A structured procurement folders and subfolders system has been established to maintain all relevant documentation. Management is actively working with consultants to update policies and procedures. Staff is scheduled to complete a structured three-session training through GFOA to enhance their understanding of federal procurement regulations and best practices. The District will continue training and development efforts in public procurement, with a particular focus on federal compliance, strengthening internal controls, improving documentation, and ensuring adherence to regulatory requirements Responsible Party: Director of Finance & Administration and Department Managers Implementation Date: Ongoing; full implementation expected by June 30, 2025

Prior Finding References

2023-004

About Procurement and Suspension and Debarment →

FY 2023-06-30

MATERIAL NONCOMPLIANCE DISCLOSEDLOW-RISK AUDITEE$4,273,290 federal awards expended

FAC accepted this audit on March 27, 2024 — management decision was due September 27, 2024.

2023-003
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2022-001QUESTIONED COSTS

The District’s internal controls over compliance requirements did not identify ineligible costs applied to four separate Federal Transit Administration (FTA) grants as follows.  Section 5307 Grant Award CA-2020-173-01: The District overclaimed Route 42 and Woodland fixed route operating expenses that should have been reimbursed by a local match as required by other FTA grants applied to the same routes, resulting in ineligible costs of $1,073,260 being charged to the program. Questioned Costs: $1,073,260.  Section 5307 Grant Award CA-2022-140-01: The District overclaimed Route 42 expansion fixed route operating expenses that should have been reimbursed by a local match as the wrong federal percentage was applied in the claims, resulting in ineligible costs of $33,129 being charged to the program. Questioned Costs: $33,129.  Section 5307 Grant Award CA-2022-147-04: The District overclaimed communication expenses for Woodland paratransit operating routes, resulting in ineligible costs of $12,513 being charged to the program. Questioned Costs: Ineligible costs were below the $25,000 floor for questioned costs under 2 CFR Part 200, Subpart F (Uniform Guidance), Section 200.516.  Section 5307 Grant Awards CA-2022-204-01 and CA-2021-162-03: The District claimed engine overhaul expenses that did not qualify as preventative maintenance costs allowed by the terms and conditions of the grant, resulting in ineligible costs of $17,902 being charged to the program. Questioned Costs: Ineligible costs were below the $25,000 floor for questioned costs under 2 CFR Part 200, Subpart F (Uniform Guidance), Section 200.516. Criteria: 2 CFR Part 200, Subpart E (Uniform Guidance) Section 200.303 states that “The nonfederal entity must: (a) 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.” Cause: Several federal grants applied to these routes had local match requirements that were not captured by the District’s review procedures due to recent staff turnover and lack of documented procedures to track expenses charged to all funding sources combined. Not all paratransit operating expenses were reported and tracked separately in the allocation spreadsheet leading to expenses being double claimed under different grants for different purposes. This is due to the allocation spreadsheet not having a summary page totaling all expenses charged to programs to make sure the total expenses allocated agree to the total population of expenses allocated. Effect: Expenses were charged to more than one grant when filing claims and ineligible costs were applied, resulting in the overclaimed amounts cited above. Context: The ineligible costs were discovered through reconciliation of the operating expenses and capital costs from the claims to the general ledger. It was noted that the District did not have any FTA awards for capital maintenance during the year. The overclaimed amounts of $1,073,260, $33,129, and $12,513 have been removed from revenue as the FTA has currently approved the District claiming the expenses under different grants. There were potentially additional operating expenses under Paratransit services that could have offset some of these overclaimed amounts. The ineligible costs of $17,902 have been submitted to the FTA through a budget revision to allow for capital funding under the two related awards and is currently pending FTA approval. Recommendation: We recommend the District develop written procedures for allocating expenses to routes and purposes used to claim expenses under federal grants and to track the different funding sources applied. A summary tab should be added to the allocation spreadsheet to sum amounts for each route computed on separate tabs on the spreadsheet to make it easier to reconcile total operating expenses, preventive maintenance, insurance, communications and other expenses allocated to the population of expenses in the general ledger. View of Responsible Officials and Planned Corrective Action: Management’s response and planned corrective action is included at the Corrective Action Plan end of this report.

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Full finding narrative

Finding 2023-003 – Material Weakness AL No: 20.507 Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Formula Grants - Direct Award Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles. Condition: The District’s internal controls over compliance requirements did not identify ineligible costs applied to four separate Federal Transit Administration (FTA) grants as follows.  Section 5307 Grant Award CA-2020-173-01: The District overclaimed Route 42 and Woodland fixed route operating expenses that should have been reimbursed by a local match as required by other FTA grants applied to the same routes, resulting in ineligible costs of $1,073,260 being charged to the program. Questioned Costs: $1,073,260.  Section 5307 Grant Award CA-2022-140-01: The District overclaimed Route 42 expansion fixed route operating expenses that should have been reimbursed by a local match as the wrong federal percentage was applied in the claims, resulting in ineligible costs of $33,129 being charged to the program. Questioned Costs: $33,129.  Section 5307 Grant Award CA-2022-147-04: The District overclaimed communication expenses for Woodland paratransit operating routes, resulting in ineligible costs of $12,513 being charged to the program. Questioned Costs: Ineligible costs were below the $25,000 floor for questioned costs under 2 CFR Part 200, Subpart F (Uniform Guidance), Section 200.516.  Section 5307 Grant Awards CA-2022-204-01 and CA-2021-162-03: The District claimed engine overhaul expenses that did not qualify as preventative maintenance costs allowed by the terms and conditions of the grant, resulting in ineligible costs of $17,902 being charged to the program. Questioned Costs: Ineligible costs were below the $25,000 floor for questioned costs under 2 CFR Part 200, Subpart F (Uniform Guidance), Section 200.516. Criteria: 2 CFR Part 200, Subpart E (Uniform Guidance) Section 200.303 states that “The nonfederal entity must: (a) 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.” Cause: Several federal grants applied to these routes had local match requirements that were not captured by the District’s review procedures due to recent staff turnover and lack of documented procedures to track expenses charged to all funding sources combined. Not all paratransit operating expenses were reported and tracked separately in the allocation spreadsheet leading to expenses being double claimed under different grants for different purposes. This is due to the allocation spreadsheet not having a summary page totaling all expenses charged to programs to make sure the total expenses allocated agree to the total population of expenses allocated. Effect: Expenses were charged to more than one grant when filing claims and ineligible costs were applied, resulting in the overclaimed amounts cited above. Context: The ineligible costs were discovered through reconciliation of the operating expenses and capital costs from the claims to the general ledger. It was noted that the District did not have any FTA awards for capital maintenance during the year. The overclaimed amounts of $1,073,260, $33,129, and $12,513 have been removed from revenue as the FTA has currently approved the District claiming the expenses under different grants. There were potentially additional operating expenses under Paratransit services that could have offset some of these overclaimed amounts. The ineligible costs of $17,902 have been submitted to the FTA through a budget revision to allow for capital funding under the two related awards and is currently pending FTA approval. Recommendation: We recommend the District develop written procedures for allocating expenses to routes and purposes used to claim expenses under federal grants and to track the different funding sources applied. A summary tab should be added to the allocation spreadsheet to sum amounts for each route computed on separate tabs on the spreadsheet to make it easier to reconcile total operating expenses, preventive maintenance, insurance, communications and other expenses allocated to the population of expenses in the general ledger. View of Responsible Officials and Planned Corrective Action: Management’s response and planned corrective action is included at the Corrective Action Plan end of this report.

Corrective Action Plan

Finding 2023-003 – Material Weakness AL No: 20.507 Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Formula Grants - Direct Award Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles. Condition: The District’s internal controls over compliance requirements did not identify ineligible costs applied to four separate Federal Transit Administration (FTA) grants as follows. • Section 5307 Grant Award CA-2020-173-01: The District overclaimed Route 42 and Woodland fixed route operating expenses that should have been reimbursed by a local match as required by other FTA grants applied to the same routes, resulting in ineligible costs of $1,073,260 being charged to the program. Questioned Costs: $1,073,260. • Section 5307 Grant Award CA-2022-140-01: The District overclaimed Route 42 expansion fixed route operating expenses that should have been reimbursed by a local match as the wrong federal percentage was applied in the claims, resulting in ineligible costs of $33,129 being charged to the program. Questioned Costs: $33,129. Section 5307 Grant Award CA-2022-147-04: The District overclaimed communication expenses for Woodland paratransit operating routes, resulting in ineligible costs of $12,513 being charged to the program. Questioned Costs: Ineligible costs were below the $25,000 floor for questioned costs under 2 CFR Part 200, Subpart F (Uniform Guidance), Section 200.516. • Section 5307 Grant Awards CA-2022-204-01 and CA-2021-162-03: The District claimed engine overhaul expenses that did not qualify as preventative maintenance costs allowed by the terms and conditions of the grant, resulting in ineligible costs of $17,902 being charged to the program. Questioned Costs: Ineligible costs were below the $25,000 floor for questioned costs under 2 CFR Part 200, Subpart F (Uniform Guidance), Section 200.516. Criteria: 2 CFR Part 200, Subpart E (Uniform Guidance) Section 200.303 states that “The nonfederal entity must: (a) 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.” Cause: Several federal grants applied to these routes had local match requirements that were not captured by the District’s review procedures due to recent staff turnover and lack of documented procedures to track expenses charged to all funding sources combined. Not all paratransit operating expenses were reported and tracked separately in the allocation spreadsheet leading to expenses being double claimed under different grants for different purposes. This is due to the allocation spreadsheet not having a summary page totaling all expenses charged to programs to make sure the total expenses allocated agree to the total population of expenses allocated. Effect: Expenses were charged to more than one grant when filing claims and ineligible costs were applied, resulting in the overclaimed amounts cited above. Context: The ineligible costs were discovered through reconciliation of the operating expenses and capital costs from the claims to the general ledger. It was noted that the District did not have any FTA awards for capital maintenance during the year. The overclaimed amounts of $1,073,260, $33,129, and $12,513 have been removed from revenue as the FTA has currently approved the District claiming the expenses under different grants. There were potentially additional operating expenses under Paratransit services that could have offset some of these overclaimed amounts. The ineligible costs of $17,902 have been submitted to the FTA through a budget revision to allow for capital funding under the two related awards and is currently pending FTA approval. Recommendation: We recommend the District develop written procedures for allocating expenses to routes and purposes used to claim expenses under federal grants and to track the different funding sources applied. A summary tab should be added to the allocation spreadsheet to sum amounts for each route computed on separate tabs on the spreadsheet to make it easier to reconcile total operating expenses, preventive maintenance, insurance, communications and other expenses allocated to the population of expenses in the general ledger. View of Responsible Officials and Planned Corrective Action: Management acknowledges the audit finding and agrees with the recommendation. The District is taking immediate corrective action by training staff and seeking temporary assistance to support operations during ongoing training and improvement. While the new financial system aimed to enhance our processes and efficiencies, we recognize the need to modify the general ledger processes to better detect required transactions. The District will focus promptly on resolving these issues to prevent future errors and oversights. Further, we will prioritize reviewing all grant award agreements and collaborating closely with our grant program coordinators to ensure compliance and accuracy in grant-related activities.

Prior Finding References

2022-001

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2023-004
Procurement & Suspension/Debarment
MATERIAL WEAKNESSMODIFIED OPINION

The District was unable to provide documentation that the procurement of the CNG tank replacement project for five Orion buses exceeding the simplified acquisition threshold of $250,000 was approved by the Board. There is documentation that an invitation for bid (IFB) was released for the project, but only one bid was received and the District awarded the contract to the sole bidder. Missing documentation includes support of the rationale to approve the contract absent evidence of full and open competition. The District was also not able to provide the request for proposal for review. Criteria: 2 CFR Part 200 Subpart E (Uniform Guidance) states the following:  Section 200.318(a) states that “The non-federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or service required under a Federal award or subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in Sections 200.317 through 200.327.”  Section 200.318(i) states that “The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.”  Section 200.320(c) states that “There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold…; (2) The item is available only from a single source; (3) The public exigency or emergency for the retirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non- Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate.”  Section 200.324(a) states that “The non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals.” Cause: Staff turnover at the District and the need for the project to be completed by a certain date to avoid the buses losing certification led to the lack of adequate records being maintained. Effect: The District was unable to prove it was in compliance with the Uniform Guidance regarding open competition on procurements. Context: The CNG tank replacement needed to be completed by a certain timeframe in order for the buses to be operational, so not every step was documented. The awarded contract was signed on the date of a Board meeting, but the Board minutes did not document that this contract was reviewed nor approved by the Board. Recommendation: We recommend the District establish a procurement folder on its server with subfolders for each individual procurement where documentation of each procurement is maintained, including advertising of the procurement, requests for proposals, proposals received, analysis of reasons for selecting the winning bid, executed contract, certifications by contractor if not part of proposal or executed contract, management report to board recommending which bid should be approved, board resolution approving the winning bid and for contracts under $250,000 a memo or form documenting bids received and reason for selecting the bid, including reasons for not selecting the lowest bid if applicable. We also recommend training be provided to staff that work on procurements of the requirements under Uniform Guidance Section 2 CFR 200.318 to 200.326. View of Responsible Officials and Planned Corrective Action: Management’s response and planned corrective action is included at the Corrective Action Plan end of this report.

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Full finding narrative

Finding 2023-004 – Material Weakness AL No: 20.507 Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Formula Grants - Direct Award. Compliance Requirement: Procurement, Suspension and Debarment. Condition: The District was unable to provide documentation that the procurement of the CNG tank replacement project for five Orion buses exceeding the simplified acquisition threshold of $250,000 was approved by the Board. There is documentation that an invitation for bid (IFB) was released for the project, but only one bid was received and the District awarded the contract to the sole bidder. Missing documentation includes support of the rationale to approve the contract absent evidence of full and open competition. The District was also not able to provide the request for proposal for review. Criteria: 2 CFR Part 200 Subpart E (Uniform Guidance) states the following:  Section 200.318(a) states that “The non-federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or service required under a Federal award or subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in Sections 200.317 through 200.327.”  Section 200.318(i) states that “The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.”  Section 200.320(c) states that “There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold…; (2) The item is available only from a single source; (3) The public exigency or emergency for the retirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non- Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate.”  Section 200.324(a) states that “The non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals.” Cause: Staff turnover at the District and the need for the project to be completed by a certain date to avoid the buses losing certification led to the lack of adequate records being maintained. Effect: The District was unable to prove it was in compliance with the Uniform Guidance regarding open competition on procurements. Context: The CNG tank replacement needed to be completed by a certain timeframe in order for the buses to be operational, so not every step was documented. The awarded contract was signed on the date of a Board meeting, but the Board minutes did not document that this contract was reviewed nor approved by the Board. Recommendation: We recommend the District establish a procurement folder on its server with subfolders for each individual procurement where documentation of each procurement is maintained, including advertising of the procurement, requests for proposals, proposals received, analysis of reasons for selecting the winning bid, executed contract, certifications by contractor if not part of proposal or executed contract, management report to board recommending which bid should be approved, board resolution approving the winning bid and for contracts under $250,000 a memo or form documenting bids received and reason for selecting the bid, including reasons for not selecting the lowest bid if applicable. We also recommend training be provided to staff that work on procurements of the requirements under Uniform Guidance Section 2 CFR 200.318 to 200.326. View of Responsible Officials and Planned Corrective Action: Management’s response and planned corrective action is included at the Corrective Action Plan end of this report.

Corrective Action Plan

Finding 2023-004 – Material Weakness AL No: 20.507 Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Formula Grants - Direct Award. Compliance Requirement: Procurement, Suspension and Debarment. Condition: The District was unable to provide documentation that the procurement of the CNG tank replacement project for five Orion buses exceeding the simplified acquisition threshold of $250,000 was approved by the Board. There is documentation that an invitation for bid (IFB) was released for the project, but only one bid was received, and the District awarded the contract to the sole bidder. Missing documentation includes support of the rationale to approve the contract absent evidence of full and open competition. The District was also not able to provide the request for proposal for review. Criteria: 2 CFR Part 200 Subpart E (Uniform Guidance) states the following: • Section 200.318(a) states that “The non-federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or service required under a Federal award or subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in Sections 200.317 through 200.327.” • Section 200.318(i) states that “The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.” • Section 200.320(c) states that “There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold…; (2) The item is available only from a single source; (3) The public exigency or emergency for the retirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate.” • Section 200.324(a) states that “The non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals.” Cause: Staff turnover at the District and the need for the project to be completed by a certain date to avoid the buses losing certification led to the lack of adequate records being maintained. Effect: The District was unable to prove it was in compliance with the Uniform Guidance regarding open competition on procurements. the buses to be operational, so not every step was documented. The awarded contract was signed on the date of a Board meeting, but the Board minutes did not document that this contract was reviewed nor approved by the Board. Recommendation: We recommend the District establish a procurement folder on its server with subfolders for each individual procurement where documentation of each procurement is maintained, including advertising of the procurement, requests for proposals, proposals received, analysis of reasons for selecting the winning bid, executed contract, certifications by contractor if not part of proposal or executed contract, management report to board recommending which bid should be approved, board resolution approving the winning bid and for contracts under $250,000 a memo or form documenting bids received and reason for selecting the bid, including reasons for not selecting the lowest bid if applicable. We also recommend training be provided to staff that work on procurements of the requirements under Uniform Guidance Section 2 CFR 200.318 to 200.326. View of Responsible Officials and Planned Corrective Action: Management agrees with the recommendation and acknowledges the importance of complying with uniform guidance regarding open and competitive procurements. Due to key staff turnover, the District could not locate documentation for the CNG tank replacement procurement to prove compliance with uniform guidance. In addition, the reason the agreement was not brought to the Board for approval could not be determined by current staff. To address the issues, the District will review its procurement and documentation procedures in addition to establishing checklists to ensure compliance and proper records retention.

About Procurement and Suspension and Debarment →

FY 2022-06-30

LOW-RISK AUDITEE$2,136,937 federal awards expended

FAC accepted this audit on February 22, 2023 — management decision was due August 22, 2023.

2022-001
Other
SIGNIFICANT DEFICIENCY

The rate per revenue mile and rate per revenue hour as well as the actual billable hours and billable miles for one route used in the spreadsheet to compute eligible expenses under grant agreements were not consistently updated to agree to the transit contractor bills during the year, which resulted in hours and mileage based fixed costs, fuel, insurance, and communication expenses to be misallocated to eligible routes when calculating expenses eligible for reimbursement. In addition, fare revenues were allocated to routes using different denominators, resulting in a misallocation of fares subtracted from operating costs among routes when determining net expenses eligible for reimbursement. These issues were not identified by the District?s review procedures. Criteria: 2 CFR Part 200, Subpart E (Uniform Guidance) Section 200.303 states that ?The nonfederal entity must: (a) 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.? Cause: The differences in the allocation spreadsheet were not identified by the District?s review procedures due to recent staff turnover and lack of documented procedures to allocate expenses to grant agreements. Effect: Expenses were misallocated to individual routes and purposes, resulting in an overclaim of Woodland preventative maintenance expenses of $12,268 under grant CA-2022-204. Context: The District revised its allocation spreadsheet to use the correct rate per revenue mile, rate per revenue hour as well as the actual billable hours and billable miles during the audit and determined that the eligible expenses claimed for all federal awards was appropriate except for the Woodland preventative maintenance under grant CA-2022-204 where it was determined that the claim exceeded the allowable expenses by $12,268, which is under the questioned cost threshold specified by the Uniform Guidance. The grant extended into the subsequent year and expenses for the year ended June 30, 2023 could be claimed under the grant agreement. Recommendation: We recommend the District develop written procedures for allocating expenses to routes and purposes used to claim expenses under federal grants, including what data should be input into the allocation spreadsheet, the formulas used to allocate each type of expense to routes, which expenses should be allocated to each route and purpose (operating, preventive maintenance, etc.) and which expenses may not be allocated to certain routes and purposes. A summary tab should be added to the spreadsheet to sum amounts for each route computed on separate tabs on the spreadsheet to make it easier to reconcile total operating expenses, preventive maintenance, insurance, communications and other expenses to the general ledger. The District should also contact the FTA to discuss how to address the $12,268 amount overclaimed. View of Responsible Officials and Planned Corrective Action: Management?s response and planned corrective action is included at the Corrective Action Plan end of this report.

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Finding 2022-001 ? Significant Deficiency ? Internal Control Over Compliance AL No: 20.507 Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Formula Grants - Direct Award Award Nos.: All awards under Assistance List (AL) Number 20.507 Condition: The rate per revenue mile and rate per revenue hour as well as the actual billable hours and billable miles for one route used in the spreadsheet to compute eligible expenses under grant agreements were not consistently updated to agree to the transit contractor bills during the year, which resulted in hours and mileage based fixed costs, fuel, insurance, and communication expenses to be misallocated to eligible routes when calculating expenses eligible for reimbursement. In addition, fare revenues were allocated to routes using different denominators, resulting in a misallocation of fares subtracted from operating costs among routes when determining net expenses eligible for reimbursement. These issues were not identified by the District?s review procedures. Criteria: 2 CFR Part 200, Subpart E (Uniform Guidance) Section 200.303 states that ?The nonfederal entity must: (a) 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.? Cause: The differences in the allocation spreadsheet were not identified by the District?s review procedures due to recent staff turnover and lack of documented procedures to allocate expenses to grant agreements. Effect: Expenses were misallocated to individual routes and purposes, resulting in an overclaim of Woodland preventative maintenance expenses of $12,268 under grant CA-2022-204. Context: The District revised its allocation spreadsheet to use the correct rate per revenue mile, rate per revenue hour as well as the actual billable hours and billable miles during the audit and determined that the eligible expenses claimed for all federal awards was appropriate except for the Woodland preventative maintenance under grant CA-2022-204 where it was determined that the claim exceeded the allowable expenses by $12,268, which is under the questioned cost threshold specified by the Uniform Guidance. The grant extended into the subsequent year and expenses for the year ended June 30, 2023 could be claimed under the grant agreement. Recommendation: We recommend the District develop written procedures for allocating expenses to routes and purposes used to claim expenses under federal grants, including what data should be input into the allocation spreadsheet, the formulas used to allocate each type of expense to routes, which expenses should be allocated to each route and purpose (operating, preventive maintenance, etc.) and which expenses may not be allocated to certain routes and purposes. A summary tab should be added to the spreadsheet to sum amounts for each route computed on separate tabs on the spreadsheet to make it easier to reconcile total operating expenses, preventive maintenance, insurance, communications and other expenses to the general ledger. The District should also contact the FTA to discuss how to address the $12,268 amount overclaimed. View of Responsible Officials and Planned Corrective Action: Management?s response and planned corrective action is included at the Corrective Action Plan end of this report.

Corrective Action Plan

Federal Grantor: US Department of Transportation, Federal Transit Administration, Federal Transit Formula Grants, Direct Award, All Award under Assistance List (AL) Number 20.507 Effect: Expenses were misallocated to individual routes and purposes, resulting in an overclaim of Woodland preventative maintenance expenses of $12,268 under grant CA-2022-204. Auditor Recommendation: We recommend the District develop written procedures for allocating expenses to routes and purposes used to claim expenses under federal grants, including what data should be input into the allocation spreadsheet, the formulas used to allocate each type of expense to routes, which expenses should be allocated to each route and purpose (operating, preventive maintenance, etc.) and which expenses may not be allocated to certain routes and purposes. A summary tab should be added to the spreadsheet to sum amounts for each route computed on separate tabs on the spreadsheet to make it easier to reconcile total operating expenses, preventive maintenance, insurance, communications and other expenses to the general ledger. The District should also contact the FTA to discuss how to address the $12,268 amount overclaimed. YCTD Contact Person Responsible for the Corrective Action: Leo Levenson, Inteirm CFO, Llevenson@yctd.org. Management Response and Corrective Action Plan: YCTD concurs with the finding and recommendation. YCTD has already contacted the FTA regional office and followed their guidance on how to return the $12,268 amount overclaimed. YCTD will formalize new written procedures and summary spreadsheet tabs as recommended by the auditor, with a target date for completion of March 31, 2023.

About Other →

FY 2021-06-30

LOW-RISK AUDITEE$6,597,864 federal awards expended

FAC accepted this audit on April 14, 2022 — management decision was due October 14, 2022.

2021-001
Other
SIGNIFICANT DEFICIENCY

The grant expenses reported on the Schedule of Expenditures of Federal Awards (SEFA) excluded grant accrual adjustments for a major program award, excluded two federal grants, and had grant award numbers that did not agree to the grant agreements. Criteria: 2 CFR Part 200, Subpart F (Uniform Guidance) Section 200.502 states, ?The auditee should prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee?s financial statements.? Internal controls over the SEFA should be in place ensure accrual basis expenses incurred under the federal program are properly reported as expenses on the SEFA and are properly reported as revenue in the financial statements prior to the start of the single audit. Cause: Expenses reported on the SEFA were not fully reconciled to all federal revenue accounts in the general ledger. Effect: Adjustments were needed to properly report expenses on the SEFA and federal revenues in the financial statements. If expenses are not properly reported on the SEFA prior to the start of the single audit, the auditor could omit expenses from testing, which would result in the District's single audit not complying with audit standards. Recommendation: We recommend the District reconcile grant expenses in the general ledger to the SEFA and revenue in the financial statements and have a second member of management review the general ledger detail, grant agreements and other information used to prepare the SEFA prior to the start of the audit in the future. View of Responsible Officials and Planned Corrective Action: Management?s response and planned corrective action is included at the end of this report.

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Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Formula Grants - Direct Award Award Nos.: CA-2020-223-00 Condition: The grant expenses reported on the Schedule of Expenditures of Federal Awards (SEFA) excluded grant accrual adjustments for a major program award, excluded two federal grants, and had grant award numbers that did not agree to the grant agreements. Criteria: 2 CFR Part 200, Subpart F (Uniform Guidance) Section 200.502 states, ?The auditee should prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee?s financial statements.? Internal controls over the SEFA should be in place ensure accrual basis expenses incurred under the federal program are properly reported as expenses on the SEFA and are properly reported as revenue in the financial statements prior to the start of the single audit. Cause: Expenses reported on the SEFA were not fully reconciled to all federal revenue accounts in the general ledger. Effect: Adjustments were needed to properly report expenses on the SEFA and federal revenues in the financial statements. If expenses are not properly reported on the SEFA prior to the start of the single audit, the auditor could omit expenses from testing, which would result in the District's single audit not complying with audit standards. Recommendation: We recommend the District reconcile grant expenses in the general ledger to the SEFA and revenue in the financial statements and have a second member of management review the general ledger detail, grant agreements and other information used to prepare the SEFA prior to the start of the audit in the future. View of Responsible Officials and Planned Corrective Action: Management?s response and planned corrective action is included at the end of this report.

Corrective Action Plan

Finding: 2021-001 Federal Grantor: US Department of Transportation, Federal Transit Administration, Federal Transit Formula Grants - Direct Award, Award No: CA-2020-223-00 Finding: The grant expenses reported on the Schedule of Expenditures of Federal Awards (SEFA) excluded grant accrual adjustments for a major program award, excluded two federal grants, and had grant award numbers that did not agree to the grant agreements. Auditor Recommendation: We recommend the District reconcile grant expenses in the general ledger to the SEFA and revenue in the financial statements and have a second member of management review the general ledger detail, grant agreements and other information used to prepare the SEFA prior to the start of the audit in the future. YCTD Contact Person Responsible for the Corrective Action: Autumn Bernstein, Executive Director, Abernstein@yctd.org. Management Response and Corrective Action Plan: YCTD concurs with the finding and recommendation. YCTD has designated a financial staff member to reconcile grant expenses in the general ledger to the SEFA. The Deputy Director, Finance and Administration position will be tasked with reviewing the general ledger detail, grant agreements, and other information used to prepare the SEFA prior to the start of future financial audits. The Deputy Director, Finance and Administration position is currently vacant but is anticipated to be filled prior to the preparation of the FY 2021-22 single audit materials. If the position is not filled at the time of FY 2021-22 single audit preparation, the Deputy Director, Operations will be responsible for reviewing YCTD?s SEFA and underlying ledger and grant information prior to submission of the SEFA to auditors. These assignments are effective immediately are anticipated to support submission of the YCTD FY 2021-22 SEFA to auditors by 10/31/22.

About Other →

FY 2020-06-30

LOW-RISK AUDITEE$8,427,841 federal awards expendedNo findings recorded this year

FAC accepted this audit on January 5, 2021 — management decision was due July 5, 2021.

FY 2019-06-30

LOW-RISK AUDITEE$3,797,734 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 4, 2020 — management decision was due September 4, 2020.

FY 2018-06-30

LOW-RISK AUDITEE$5,906,044 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 26, 2019 — management decision was due September 26, 2019.

FY 2017-06-30

LOW-RISK AUDITEE$4,004,670 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 22, 2018 — management decision was due September 22, 2018.

FY 2016-06-30

LOW-RISK AUDITEE$4,380,904 federal awards expendedNo findings recorded this year

FAC accepted this audit on February 28, 2017 — management decision was due August 28, 2017.

Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.

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