Village of Rantoul

2024 – 003 Suspension and Debarment Federal agency: U.S. Department of Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Award Period: March 3, 2021 – December 31, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). Condition: The Village did not maintain records the vendor was not suspended or debarred prior to entering into the transactions. Questioned costs: None Context: 5 of 5 tested for suspension and debarment documentation. Cause: The processes for suspension and debarment were not properly followed during the current fiscal year. Proper documentation was not retained. Village policies have not been updated yet. Effect: May result in disallowed cost if grant requirements are not followed. Repeat finding: This is a repeat finding. Prior year finding number was 2023-003. Recommendation: We recommend the Village carefully review federal suspension and debarment requirements for proper documentation needed. The Village should consider use of a Federal procurement checklist. Views of responsible officials: There is no disagreement with the audit finding.

2024 – 004 Reporting Federal agency: U.S. Department of Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Award Period: March 3, 2021 – December 31, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include the annual report be reviewed, and this review should be documented. Condition: The Village did not maintain record that the annual report was reviewed and approved by an individual other than the preparer. Questioned costs: None Context: This issues was noted in 1 of 1 reports tested. Cause: The Village does not have a formal control in place to ensure the annual reports are reviewed by an individual other than the preparer. Effect: May result in inaccurate reporting and allowable costs being charged to Federal programs. Repeat finding: The finding is a partial repeat of a finding in the prior year. The prior year finding number was 2023-004. Recommendation: We recommend the Village strengthen internal controls over the review process of the annual grant reporting prior to the report submission. This review should be documented. Views of responsible officials: There is no disagreement with the audit finding.

Federal agency: U.S. Department of Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Period: March 3, 2021 – December 31, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). Condition: The Village did not complete the suspension and debarment procedures prior to entering into the transactions. Questioned costs: None Context: The Village’s suspension and debarment policy has not been completely followed per the Uniform Grant Guidance. This was noted in the 2 out of 2 items tested. Cause: The processes for suspension and debarment where updated and approved near the end of the current fiscal year as a result of the prior year finding. However, the updated procedures were not implemented for the full year which resulted in the majority of the current year’s transactions following the old procedures. Effect: A lack of internal control procedures can lead to noncompliance with grant requirements. Repeat finding: No Recommendation: We recommend following the requirements for suspension and debarment per the Uniform Guidance, including the date performed and retain required documentation. Views of responsible officials: The Village recognizes and accepts the audit finding as presented

Federal agency: U.S. Department of Treasury Federal program title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Period: March 3, 2021 – December 31, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include ensuring that supporting calculations are accurate. Condition: The Village could not provide proper support summarizing/reconciling its allowable costs totaling $15,281, when reporting the funds, it spent under COVID-19 State and Local Fiscal Recovery Funds during the fiscal year. In addition, there is no formal documentation of the review being completed. Questioned costs: $15,281 Context: The Village errors on the amounts reported in 1 out of 1 report tested, with $15,281 lacking proper support during the fiscal year. Cause: Costs were paid accurately to vendors, but the Village could not provide proper support for the amount charged to the grant. Effect: May result in unallowable costs being charged to Federal programs. Repeat finding: No. Recommendation: We recommend the Village review its procedures relative to allocating costs and reviewing support provided for reporting to Federal programs. Views of responsible officials: The Village recognizes and accepts the audit finding as presented.

Federal Agency: U.S. Department of Commerce Federal Program Name: EDA Revolving Loan Fund Assistance Listing Number: 11.307 Federal Award Identification Number and Year: 06-49-02663 and Ongoing Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: May 1, 2021 to April 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: Federal guidelines require internal control over specific requirements related to reporting of the EDA Revolving Loan Fund. The form ED-209 report must be submitted at a frequency as directed by EDA (13 CRF section 307.14(a)). Condition: During our testing over the semi-annual filings, it was noted the filings were not submitted timely by the due date noted within the electronic filing system. Context: This was noted during the testing over electronic filings completed during fiscal year 2022. Questioned Costs: None Cause: Management does not have a process in place to ensure required filings are completed and submitted by the due date noted in the filing system. Effect: The lack of timely filings could result in delay or denial of future funding due to noncompliance. Repeat Finding: N/A Recommendation: We recommend that the Village implement a process to ensure all required filings are completed timely. There should be a review process in place to ensure compliance with grant requirements.

Federal guidelines require internal control over specific requirements related to rehabilitation projects. During our testing over rehabilitation project files, there was no evidence in two project files of the lead-based review and in one file there was no support for the work being completed. Management does not have a review process in place to ensure all required documentation and reviews are included within each rehabilitation project file. The rehabilitation projects could be noncompliant with the regulations and requirements of the Department of Housing and Urban Development. We recommend that the Village implement the use of a checklist, which includes all required support and documentation to be maintained in each project file. There should also be a complete review of all project files by someone other than the individual who monitors or oversees the project activities.

Federal guidelines require internal control over specific requirements related to the issuance of new loans. During out testing over new loans, there was no evidence in the loan file of a bank turn-down letter or referral from the declining bank showing credit was not available from other sources. Management received a verbal notification from the declining bank, however did not request written documentation or turn-down letter. Funds could be disbursed to an ineligible loan recipient. We recommend that the Village review the special provisions required for this program and ensure polices are in place to comply with them. The bank turn-down letter should be included in the file or other written support from the declining bank.

Federal guidelines require internal control over federal reporting requirements. We noted in the audit process the semi-annual reports completed are not reviewed by someone other than the preparer. There have been changes in the leadership positions and the review process was not completed in the past. An error could be made on the federal financial report and go undetected. We recommend that the Village have a process in place for all federal reports to be reviewed by an appropriate person other than the preparer. That review should be documented with a signature or initials and the date.

Federal guidelines for this program require review of certified payrolls related to construction projects. We noted in the audit process, that certified payrolls were not obtained and reviewed for construction projects. The lack of review of certified payrolls was an oversight. Lack of proper review of payrolls can allow for noncompliance with grant requirements. We recommend that the Village review the special provisions required for this program and ensure policies are in place to comply with them. These reviews of certified payrolls should be documented.