City of Dexter, Missouri

Federal Program: Coronavirus State and Local Fiscal Recovery Funds (21.027). Criteria: Uniform Guidance requires policies related to cash management, cost allowability, procurement and conflict of interest provisions, along with appropriate financial management systems and internal controls over federal awards to safeguard federal funds. Condition: Although no material noncompliance with federal grant requirements was noted, the City did not have written policies and procedures over the components of grant administration. Cause: The City had no written policies and relied on each project director receiving grant funding to comply with all applicable compliance requirements. Effect: The federal government believes that not having written policies and procedures for grant administration increases the risk that the City will not comply with applicable compliance requirements. Questioned Costs: None. Context: Total federal grant expenditures totaled $2,137,798 during the fiscal year ended June 30, 2024. Repeat Finding: No. Recommendation: We recommend the City develop written policies and procedures related to cash management, cost allowability, procurement, and conflict of interest provisions for federal funds it receives. Views of Responsible Officials and Planned Corrective Actions: The City agrees with the recommendation and is developing the appropriate written policies.

Federal Program: Coronavirus State and Local Fiscal Recovery Funds (21.027). Criteria: One of the required reports for the program was filed late. Condition: The report was due April 30, 2024 but was not filed until August 8, 2024. Cause: The City was unable to log into the portal required to upload and file the report. They finally received technical support from the federal government to access the portal, but the deadline had already passed. Effect: The effect was that the report was not filed until after the required deadline. Questioned Costs: None. Context: This was the only report tested that was filed late. Repeat Finding: No. Recommendation: The City should ensure that all reports are filed timely. Views of Responsible Officials and Planned Corrective Actions: The City agrees with the recommendation.

Federal Program: Coronavirus State and Local Fiscal Recovery Funds (21.027). Criteria: According to 2 CFR Section 180.300, when a non-federal entity enters into a covered transactions with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended, debarred, or otherwise excluded. Condition: The City had transactions in excess of $25,000 with two vendors in which they did not verify that the entity was not suspended, debarred, or otherwise excluded. Cause: The City was not aware of this requirement. Effect: The City was at risk of making material payments to a vendor who is not allowed to do business with the federal government. There was no noncompliance, but there was no internal control in place to prevent noncompliance. Questioned Costs: None. Context: Payments to the vendors totaled $1,072,854. As noted above, there was no noncompliance, but there were no internal controls in place to ensure compliance. Repeat Finding: No. Recommendation: We recommend the City check the excluded parties list system or collect certifications from any vendor in which the City expects to spend more than $25,000 of federal grant funds for the year. Views of Responsible Officials and Planned Corrective Actions: The City agrees with the recommendation and will verify vendor status before making qualified payments.