Village of Hales CornersLocal Government

Finding 2023-002: Material Weakness - Internal Control Over Procurement, Suspension and Debarment Program: COVID-19 State & Local Fiscal Recovery Funds Grantor Agencies: U.S. Department of Treasury & WI Department of Health Services Assistance Listing Number: 21.027 Criteria: For federal awards after January 1, 2018, guidance provided in 2 CFR part 200.318 requires nonfederal entities to establish and follow their own documented procurement procedures that conform to applicable federal law and standards. 2 CFR part 200.320 includes different allowable methods of procurement. There are also requirements to verify the vendors are not suspended or debarred. Condition/Context: During our testing for this program, we noted that the Village did not have a written procurement policy to conform with Uniform Guidance requirements. There was not a system in place to track and document the procurement process and support the contracting decisions made. As a result, we were unable to verify if the Village followed the necessary federal procurement standards. Cause: The Village was not aware that a written policy was required to be in place outside of the terms and condition in the grant agreement. Effect: Without an adequate policy in place, procurement procedures may not adhere to requirements of federal awards. Questioned Costs: None noted. Recommendation: Program personnel should become familiar with the procurement, suspension and debarment rules for Federal programs and implement a formal written policy to conform with Uniform Guidance requirements. The Village should also create a system to track projects that were procured during the year to ensure they are in compliance with their policy. Management response and Corrective Action Plan: Management agrees with the finding. A tracking procedure has been developed and a written procurement policy will be approved prior to the end of fiscal 2024 to further define procurement processes to align with Federal program standards and Village ordinance to address this deficiency.

Finding 2023-003: Material Weakness - Internal Control Over Reporting Program: COVID-19 State & Local Fiscal Recovery Funds Grantor Agencies: U.S. Department of Treasury & WI Department of Health Services Assistance Listing Number: 21.027 Criteria: All required reporting should be reviewed with proper detail to ensure they are completed accurately and properly approved prior to submission. Condition/Context: Of the three reports selected for testing, none included documentation of proper review. Additionally, the two reports tested related to the funding passed through DHS were not completed with accuracy or on a timely basis. As a result of this, both reports erroneously included expenditures incurred after the reporting period. Overall, the expenditures do agree to the amount awarded by DHS despite these discrepancies of when the expenditures were reported. Cause: The Village was not aware of the requirement to complete and retain documentation of review prior to submitting these reports. There also was not proper review to identify and correct these reporting errors prior to submission. Effect: The reports could contain inaccurate information leading to an impact on future grant funding. Questioned Costs: None noted. Recommendation: We recommend the Village implement procedures to review reporting prior to submission. This should include verification that the report is accurate as compared to the underlying data, mathematically correct and submitted timely. Documentation of this review should be retained on file. Management response and Corrective Action Plan: Management agrees with the finding. Village Management staff will prepare the support document, the Village Administrator will review the support and submit to the appropriate approving Department for their submittals to the programs on a month end basis.