CITY OF BENTONLocal Government

Finding 2021-003 Federal program Airport Improvement Program (CFDA # 20.106) Criteria or specific requirement Per the terms of Agreement No. 20-0327-18180, between the State of Illinois, Illinois Department of Transportation, Aeronautics and the City of Benton, the City is required to submit quarterly financial reports on Form BOBS 2832. The form instructions requires that each applicable element be completed. Condition and context Per examination of the Periodic Financial Report for the periods ending September 30, 2020, December 31, 2020 and March 31, 2021, it was noted that column (p) related to the period to date match amount was not completed on any of the three reports. Cause The City inadvertently omitted the accumulated match amount from the Periodic Financial Reports. Effect or potential effect The City?s reports were incomplete when submitted. A statistically valid sample was used N/A Questioned costs N/A Repeat finding, prior audit finding number N/A Recommendation We recommend that the Periodic Report instructions be reviewed at the time that the Periodic Reports are prepared to ensure they are completed as required. Management?s response Management has informed us that the city is looking into engaging a firm to take over management of the grants to ensure that all reports are completed as requested.

Federal program Assistance to Firefighters Grant (CFDA # 97.044) Criteria or specific requirement 2 CFR Part 200 ? Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart D ? Post Federal Award Requirements ? 200.313(d)(1) Equipment ? Management requirements. Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Condition and context The City?s property and equipment records did not include the source of funding for the property, who holds title, the percentage of Federal participation in the project costs for the Federal award under which the property was acquired, and the use and condition of the property. This is the first time the City has received a grant for equipment therefore they were not aware of the additional recordkeeping requirements. Cause Per discussion with the Fire Chief and Treasurer, they were not aware of the additional record keeping requirements as this is the first award they have received for equipment or real property. Effect or potential effect The City is not in compliance with the record keeping requirements of 2 CFR section 200.313(d)(1) which may result in funds not being returned to the grantor or returned in an incorrect amount upon disposition of the asset. A statistically valid sample was used N/A Questioned costs N/A Repeat finding, prior audit finding number N/A Recommendation We recommend that a schedule be maintained of all equipment and real property purchased in whole or in part with federal funds which includes all the information required by 2CFR section 200.313(d)(1). Management?s response Management has informed us that a third party maintains the asset listing and that they have been instructed to include all required information with the asset records. This was implemented in April 2022.

Federal program Assistance to Firefighters Grant (CFDA # 97.044) Criteria or specific requirement The 0MB guidance states that, "Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include those procurement 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. All nonprocurement transactions entered into by a recipient (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215." Condition and context A written policy and procedure has not been established at the City that indicates the person responsible for ensuring that vendors whom the City conducts business is not suspended or debarred from receiving federal funds. As such, neither the Finance Department nor the Fire Department were aware of who was responsible for performing the suspension and debarment check. Cause The City has not established a written policy and procedure for suspension and debarment checks related to purchases that include federal funds. Effect or potential effect The City is not compliant with the terms and conditions of the grant award. A statistically valid sample was used N/A Questioned costs N/A Repeat finding, prior audit finding number N/A Recommendation We recommend that the City design and implement a policy and procedure over suspension and debarment which includes identifying those responsible and how documentation will be maintained. Management?s response Management has informed us that the City will be developing a policy and procedure to handle the suspension and debarment requirements.

Federal program Airport Improvement Program (CFDA # 20.106) Criteria or specific requirement 2 CFR Part 200.334 ? Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Subpart D Post Federal Ward Requirements ? 200.334 ? Retention requirements for records Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition and context The Treasurer was unable to provide the award document related to the airport restriping project. We were referred to a third party who was contracted to oversee the airport improvement program and who also was unable to provide the award document. Cause The City has not designed and implemented a policy and procedure to ensure that grant records are maintained and complete. Effect or potential effect The City is not in compliance with the requirements of the Uniform Guidance. A statistically valid sample was used N/A Questioned costs N/A Repeat finding, prior audit finding number Yes, 2018-001 Recommendation We recommend that the City design and implement a policy and procedure over grant records including appointing a designated employee who will oversee the process. Management?s response Management has informed us that the City has conveyed the importance of receiving timely copies of all paper work concerning all grants to the grant administrators. They have agreed to provide all future reports and copies in a timely fashion.