City of OelweinLocal Government

Project and Expenditure Report Criteria – The Uniform Guidance, Part 200.303, requires the auditee establish and maintain effective internal control over the federal award which provides reasonable assurance the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms of the federal award. The City is required to submit an annual project and expenditures report. The Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds, requires the annual report be submitted to the U.S. Treasury by April 30, each year. Condition – The required report was submitted on time but the expended amount was incorrect. Cause – City procedures have not been established to ensure the report is submitted with the correct amount. Effect – The lack of established policies and procedures resulted in the incorrect amount submitted on the required report. Recommendation – The City should establish a policies and procedures to ensure reports are submitted timely with the correct amount in accordance with the Compliance and Reporting Guidance. Response and Corrective Action Planned – A policy and procedure will be established to ensure the annual Project and Expenditure Report is submitted with the correct amount prior to the deadline. Conclusion – Response accepted.

Special Tests and Provision Criteria – The basic requirement for use of airport revenue is that all revenues generated by a public airport must be expended for the capital or operating costs of the airport and the local airport system. The City should have a proper policy in regards to how airport revenue is to be spent. Condition – The City did not establish a policy for the use of airport revenue. Cause – The City’s management was not aware that they needed to have a policy in regards to airport revenue. Effect – The City is not in compliance with Federal regulations pertaining special tests and provisions as required by the Uniform Guidance. Recommendation – The City should establish a policy for the use of airport revenue. Corrective Action – The City will establish a policy for the use of airport revenue. Conclusion – Response accepted.

Monitoring and Reporting Program Performance Criteria ? Title 2, U.S. Code of Federal Regulations Part 200.329 Monitoring and Reporting Program Performance, the City was required to submit Non-construction performance reports (1) The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. ?The recipient is responsible for completing and submitting a Programmatic Performance Report (PPR) using FEMA GO?. Condition ? The City?s management did not submit the PPR on a timely basis. Cause ? The City?s management were not aware that they needed to submit the PPR on a quarterly basis. Effect ? The City is not in compliance with Federal regulations pertaining to monitoring and reporting program performance as required by the Uniform Guidance. Recommendation ? The City should submit the PPR on a timely basis. Corrective Action ? The City has submitted the PPR after being notified by FEM and will continue to submit on time. Conclusion ? Response accepted.

Procurement Suspension & Debarment Criteria ? Title 2, U.S. Code of Federal Regulations Part 180.300 When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition ? The City?s management did not verify that the vendor was not suspended or disbarred. Cause ?The City?s management were not aware that they needed to verify that the entity was not suspended or debarred. Effect ? The City did not have a process to indicate that the vendor was not suspended or disbarred from doing business with federal funds. The City is not in compliance with Federal regulations pertaining to procurement suspension & debarment as required by the Uniform Guidance. Recommendation ? The City should verify that each vendor or contracts paid with federal awards, are not suspended by checking the System for Awards Management (SAM) Exclusion available at SAM.gov. Corrective Action ? The City was unable to check to make sure the contractor was not disbarred from federal grants. The City is working through a process to ensure all contractors are not on the disbarred list. This requirement is infrequent and may not come to the city for several years. The City will check SAMS numbers and do more work on the front end for each contractor Conclusion ? Response accepted.

Single Audit Process Criteria ? Title 2, U.S. Code of Federal Regulations ?200.501 states that an entity that expends $750,000 or more during the non-Federal entity?s fiscal year in Federal awards, they must have a single audit or program-specific audit conducted for that year in accordance with the provision in ?200.501. Condition ? The City had over $750,000 in federal expenditures in the current year and did not request an audit in accordance with Uniform Guidance. Cause ?The City?s management did not track expenditures of federal awards for the year ended June 30, 2022 to determine what federal audit requirements applied if any. Were it not for our recommendation that an Audit in accordance with Uniform Guidance was required, it may have been missed. Effect ? The City?s internal control over compliance with federal audit requirements was inadequate. Recommendation ? The City should establish a process to track the dollar amount of federal expenditures that were spent during the year to determine if an audit in accordance with uniform guidance is required. This should be done and communicated with the auditors before audit work begins. Corrective Action ? The City will work on a formal process for tracking all federal grants. The city has always been cognizant of this rule and did inform the auditors when the audit was being performed. The City Administrator feels strongly that this requirement was met. Conclusion ? Response accepted.