CITY OF MINNEOLA, KANSAS

U.S. DEPARTMENT OF AGRICULTURE SIGNIFICANT DEFICIENCY 2021-001: Water and Waste Disposal System for Rural Communities ? CFDA No. 10.760 Grant period: Year Ended December 31, 2021 Condition: The City does not have a complete set of written procurement policies and procedures, a written conflict of interest and code of conduct for employees, or a written cash management or procurement policy required by the Uniform Guidance. The lack of written procedures did not result in any material noncompliance, fraud, or abuse with respect to the major program. Criteria: The Uniform Guidance requires Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the cash management standards set out at 2 CFR Section 305 and procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the cash management and procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Cause: The City was unaware of the written cash management and procurement policy requirements required by the Uniform Guidance. Effect: An important component of internal controls is the existence of operating policies and procedures and that they are clearly understood and communicated. Without clear written policies and procedures, there is a higher risk of noncompliance with program requirements. Recommendation: Management should determine the scope of written policies needed for compliance with all federal programs and develop policies and procedures to comply with the Uniform Guidance. View of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and recommendation. The City will create necessary procedures in order to meet the Uniform Guidance requirements. Once policies are drafted, the policies will be presented to the Governing Body for review and approval.

U.S. DEPARTMENT OF AGRICULTURE SIGNIFICANT DEFICIENCY 2020-001: Water and Waste Disposal System for Rural Communities ? CFDA No. 10.760 Condition: The City does not have a complete set of written procurement policies and procedures, a written conflict of interest and code of conduct for employees, or a written cash management or procurement policy required by the Uniform Guidance. The lack of written procedures did not result in any material noncompliance, fraud, or abuse with respect to the major program. Criteria: The Uniform Guidance requires Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the cash management standards set out at 2 CFR Section 305 and procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the cash management and procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Cause: The City was unaware of the written cash management and procurement policy requirements required by the Uniform Guidance. Effect: An important component of internal controls is the existence of operating policies and procedures and that they are clearly understood and communicated. Without clear written policies and procedures, there is a higher risk of noncompliance with program requirements. Recommendation: Management should determine the scope of written policies needed for compliance with all federal programs and develop policies and procedures to comply with the Uniform Guidance. View of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and recommendation. The City will create necessary procedures in order to meet the Uniform Guidance requirements. Once policies are drafted, the policies will be presented to the Governing Body for review and approval.