MONTGOMERY COUNTYLocal Government

2023-002: Internal Control Over Schedule of Expenditures of Federal Awards Federal Grantor: U.S. Department of Justice (DOJ), U.S. Department of the Treasury (Treasury), and U.S. Department of Homeland Security (DHS) Pass-Through Grantor: Missouri Department of Public Safety Federal Assistance Listing Number: 16.738, 21.027, 21.032, 97.036, and 97.042 Program Title: Edward Byrne Memorial Justice Assistance Grant Program; Coronavirus State and Local Fiscal Recovery Funds; Local Assistance and Tribal Consistency Fund; Disaster Grants – Public Assistance (Presidentially Declared Disasters); Emergency Management Performance Grant Pass-through Entity Identifying Number: 15PBJA-22-GG-00640-MUMU-054; DR-4665-MO; EMK-2022-EP-00004-073; EMK-2023-EP-0004-063 Award Year: 2023 Questioned Costs: None Criteria: 2 CFR 200.510(b) requires auditees to prepare a schedule of expenditures of federal awards (SEFA) which must report total federal awards expended during the audit period. At a minimum, the schedule must include: expenditures by individual federal program, name of the pass-through entity and identifying number for awards not received directly from the federal government, and the total amount provided to subrecipients from each federal program. The County has not implemented proper internal controls to ensure the completeness and accuracy of the SEFA. Condition: The SEFA reported by the County in the 2024 annual budget documents contained errors in amounts of federal expenditures reported. Discrepancies in amounts reported on the 2023 SEFA and amount supported by underlying accounting records are summarized as follows: Cause: The County has not implemented a proper system of internal control over SEFA preparation, such as a reconciliation to underlying accounting records and controls for identifying and tracking expenditures of federal awards. Effect: The SEFA presented for audit did not accurately reflect the County’s actual expenditures of federal awards for the year ended December 31, 2023. Recommendation: We recommend that the County implement internal controls to ensure that the SEFA completely and accurately states the expenditures of federal awards of the County each year.

2023-003: Internal Control Over Reporting Requirements Federal Grantor: U.S. Department of the Treasury Federal Assistance Listing Number: 21.027 Program Title: Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Award Year: 2023 Questioned Costs: None Criteria: The SLFRF Compliance and Reporting Guidance requires recipients to submit annual Project and Expenditure Reports to the Department of the Treasury by April 30 of each year, reporting the amount of expenditures for the reporting period as well as cumulative expenditures. Condition: During audit fieldwork, the County Commission could not provide documentation to support that the one-time interim report or annual Project and Expenditure Reports have been properly and timely submitted to Treasury in accordance with SLFRF reporting requirements. As part of the response process the County provided a copy of the Project and Expenditure Report for the period ended March 31, 2023, which reported $0 of expenditures. The County indicated in the report that, “My jurisdiction does NOT have projects to report,” and stated in the report that, “No funds have been allocated to Government Services yet. The County has been waiting for the Final Rule before obligating to any projects.” However, the Treasurer’s Settlements for 2022 reported $1,122,531 of expenditures in the ARPA Fund in 2022 and the County had an Alternative Compliance Examination Engagement performed for the period. Cause: It appears that there was confusion regarding the reporting requirements of the SLFRF and the need to maintain documentation of the reports submitted to the Treasury portal. Effect: The County risks being out of compliance with SLFRF program reporting requirements if the proper reports are not timely and accurately submitted to Treasury. Recommendation: We recommend the County implement procedures to ensure that all required reports are properly submitted to Treasury to ensure compliance with reporting requirements of the SLFRF program and that documentation of compliance is maintained.