VILLAGE OF BELLEVUELocal Government

2025-004 LACK OF WRITTEN FEDERAL POLICIES AND PROCEDURES REQUIRED BY UNIFORM GUIDANCE Type of Finding: Material noncompliance Federal Program: Coronavirus State and Local Fiscal Recovery Funds (ALN# 21.027) Compliance Requirement: All Criteria - Per 2 CFR §200.303 and related sections (including §§200.305 and 200.318-320), non-federal entities expending federal awards must establish and maintain effective internal controls and must document policies and procedures governing compliance with applicable federal statutes, regulations, and terms of award. Condition - The Village has not developed or implemented the written policies and procedures required under the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Required documentation is absent in areas such as internal controls over compliance, cash management, procurement, and allowable costs. A similar issue was noted and reported last year as 2024-005. Cause - The Village has not formally developed Uniform Guidance-compliant policies due to limited administrative resources and competing operational priorities. Effect - The absence of formal written policies and procedures increases the risk of inconsistent or noncompliant treatment of federal expenditures. Without documented controls and expectations, the Village may fail to detect or prevent noncompliance with federal requirements in key grant administration areas. Questioned Costs - None Recommendation - We recommend that the Village adopt written policies and procedures addressing the specific requirements outlined in the Uniform Guidance. These policies should include, but not be limited to, internal controls over compliance, procurement, cash management, subrecipient monitoring (if applicable), and allowable cost determinations. Management should ensure that these policies are communicated and periodically reviewed. Views of Responsible Officials: Management agrees with the finding and will take appropriate steps to remedy noted finding.

2024-004 - Material Misstatement of the Schedule of Expenditures of Federal Awards (SEFA) Finding Type: Material weakness in internal control over compliance Federal Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Reporting Condition/Finding: The Schedule of Expenditures of Federal Awards (SEFA), as initially provided for audit, contained material misstatements. The original version of the SEFA did not accurately report the total amount of federal expenditures and required significant audit adjustments to reflect the proper award amounts and program classifications in accordance with the Uniform Guidance. Criteria: Per 2 CFR §200.510(b), the auditee must prepare a SEFA that accurately and completely discloses all federal awards expended during the fiscal year, including the name of the federal program, assistance listing number, amount expended, and applicable pass-through entities. This schedule must be prepared in accordance with GAAP and the Uniform Guidance. Cause: The misstatements were due to inadequate internal controls over the preparation and review of the SEFA. The Village lacked a formal process to ensure the completeness and accuracy of reported federal expenditures prior to submission for audit. Effect: The SEFA, as originally submitted, materially misstated the Village’s federal expenditures for the fiscal year, which could have resulted in the incorrect identification of major programs and misrepresentation of federal activity in the audit. This represents a material weakness in internal control over compliance. Recommendation: We recommend that the Village implement procedures to ensure that the SEFA is prepared using complete, reconciled grant expenditure data and that it is reviewed by a qualified individual prior to submission for audit. Supporting documentation should be maintained to substantiate amounts reported by federal program. View of Responsible Officials: Management’s response and planned corrective action can be found in the accompanying Corrective Action Plan.

2024-005 - Lack of Written Federal Policies and Procedures Required by Uniform Guidance Finding Type: Material weakness in internal control over compliance Federal Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Allowable Costs/Cost Principles, Procurement and Suspension and Debarment Condition/Finding: The Village has not developed or implemented the written policies and procedures required under the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Required documentation is absent in areas such as internal controls over compliance, cash management, procurement, and allowable costs. Criteria: Per 2 CFR §200.303 and related sections (including §§200.305 and 200.318–320), non-federal entities expending federal awards must establish and maintain effective internal controls and must document policies and procedures governing compliance with applicable federal statutes, regulations, and terms of award. Cause: The Village has not formally developed Uniform Guidance-compliant policies due to limited administrative resources and competing operational priorities. Effect: The absence of formal written policies and procedures increases the risk of inconsistent or noncompliant treatment of federal expenditures. Without documented controls and expectations, the Village may fail to detect or prevent noncompliance with federal requirements in key grant administration areas. Recommendation: We recommend that the Village adopt written policies and procedures addressing the specific requirements outlined in the Uniform Guidance. These policies should include, but not be limited to, internal controls over compliance, procurement, cash management, subrecipient monitoring (if applicable), and allowable cost determinations. Management should ensure that these policies are communicated and periodically reviewed. View of Responsible Officials: Management’s response and planned corrective action can be found in the accompanying Corrective Action Plan.