EIN: 526001156
UEI: RN4HQWTJMFZ8
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 30, 2026 (34 days from today).
What is a management decision? →Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: MD-0044 and 2021 Award Period: September 1, 2021 through December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: When a nonfederal 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. Questioned Costs: None Condition/Context: One of five vendors tested did not have proper documentation maintained to support suspension and debarment verification was performed prior to them being paid with federal funds. Per SAM.gov, there was no history of the vendor being suspended or debarred. Cause: The Commissions policies and procedures did not require documentation be maintained to verify vendors are not suspended or debarred prior to paying with Federal grant funds. Effect: The Commission could make a disbursement to a vendor that is suspended or debarred. Repeat Finding: This is a repeat finding. Recommendation: We recommend the Commission continue with the policies and procedures now established and require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: MD-0044 and 2021 Award Period: September 1, 2021 through December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: When a nonfederal 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. Questioned Costs: None Condition/Context: One of five vendors tested did not have proper documentation maintained to support suspension and debarment verification was performed prior to them being paid with federal funds. Per SAM.gov, there was no history of the vendor being suspended or debarred. Cause: The Commissions policies and procedures did not require documentation be maintained to verify vendors are not suspended or debarred prior to paying with Federal grant funds. Effect: The Commission could make a disbursement to a vendor that is suspended or debarred. Repeat Finding: This is a repeat finding. Recommendation: We recommend the Commission continue with the policies and procedures now established and require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Views of Responsible Officials: Management agrees with the finding.
Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Recommendation: We recommend the Commission continue with the policies and procedures now established and require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In April 2024, the Commission established a policy requiring documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Easton Utilities immediately began checking new vendors as part of the vendor establishment process and began the process to verify existing vendors. Easton Utilities had around 3,000 established vendors in the system, leading to a longer period to verify all vendors. This finding relates to inventory transactions. At the time of purchase, this inventory was not yet determined to be related to the grant. The inventory was purchased through Easton Utilities' standard inventory procurement process related to keeping appropriate stock to support the ongoing business. Inventory is charged to the grant at the time it is used and requisitioned out. All material requisitions are approved by an appointed responsible person within the Easton Velocity team before entered by the Accounting team. The vendor was checked for status on 8/1/2024. 92% of the inventory associated with this purchase that was charged to the grant was charged after 8/1/2024. Name of the contact person responsible for corrective action: Carrie Manuel Planned completion date for corrective action plan: Corrective action was taken April 2024.
2024-002
FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.
Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: MD-0044 and 2021 Award Period: March 11, 2021 through December 31, 2024, liquidated by December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Per 2 CFR 200.305(b)8, a payment must not be made to a recipient or subrecipient for amounts that the recipient or subrecipient withholds from contractors to assure satisfactory completion of work. Payment must be made when the recipient or subrecipient disburses the withheld funds to the contractors or to escrow accounts established to ensure satisfactory completion of work. Questioned Costs: None Condition/Context: Four of sixty general disbursements tested were related to retainage payable. These expenditures were not paid during the fiscal year and therefore should not be reported on the SEFA. Cause: The Commission did not have proper policies and procedures in place to ensure the SEFA is prepared in accordance with Uniform Grant Guidance. Effect: The Commission could overstate federal expenditures on the SEFA. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Commission establish policies and procedures over internal controls to ensure review and approval of SEFA preparation. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: MD-0044 and 2021 Award Period: March 11, 2021 through December 31, 2024, liquidated by December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Per 2 CFR 200.305(b)8, a payment must not be made to a recipient or subrecipient for amounts that the recipient or subrecipient withholds from contractors to assure satisfactory completion of work. Payment must be made when the recipient or subrecipient disburses the withheld funds to the contractors or to escrow accounts established to ensure satisfactory completion of work. Questioned Costs: None Condition/Context: Four of sixty general disbursements tested were related to retainage payable. These expenditures were not paid during the fiscal year and therefore should not be reported on the SEFA. Cause: The Commission did not have proper policies and procedures in place to ensure the SEFA is prepared in accordance with Uniform Grant Guidance. Effect: The Commission could overstate federal expenditures on the SEFA. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Commission establish policies and procedures over internal controls to ensure review and approval of SEFA preparation. Views of Responsible Officials: Management agrees with the finding.
State and Local Fiscal Recovery Funds– Assistance Listing No. 21.027 Allowable Activities and Costs - Significant Deficiency in Internal Control Over Compliance Recommendation: We recommend the Commission establish policies and procedures over internal controls to ensure review and approval of SEFA preparation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Commission will implement a SEFA preparation policy. Name of the contact person responsible for corrective action: Tracie Thomas Planned completion date for corrective action plan: May 31, 2025
Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: MD-0044 and 2021 Award Period: March 11, 2021 through December 31, 2024, liquidated by December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: When a nonfederal 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. Questioned Costs: None Condition/Context: Three of five vendors tested did not have proper documentation maintained to support suspension and debarment verification was performed prior to them being paid with federal funds. Per SAM.gov, there was no history of the vendor being suspended or debarred. Cause: The Commission’s policies and procedures did not require documentation be maintained to verify vendors are not suspended or debarred prior to paying with Federal grant funds. Effect: The Commission could make a disbursement to a vendor that is suspended or debarred. Repeat Finding: This is a repeat finding. Recommendation: We recommend the Commission continue with the policies and procedures now established and require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: MD-0044 and 2021 Award Period: March 11, 2021 through December 31, 2024, liquidated by December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: When a nonfederal 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. Questioned Costs: None Condition/Context: Three of five vendors tested did not have proper documentation maintained to support suspension and debarment verification was performed prior to them being paid with federal funds. Per SAM.gov, there was no history of the vendor being suspended or debarred. Cause: The Commission’s policies and procedures did not require documentation be maintained to verify vendors are not suspended or debarred prior to paying with Federal grant funds. Effect: The Commission could make a disbursement to a vendor that is suspended or debarred. Repeat Finding: This is a repeat finding. Recommendation: We recommend the Commission continue with the policies and procedures now established and require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Views of Responsible Officials: Management agrees with the finding.
State and Local Fiscal Recovery Funds– Assistance Listing No. 21.027 Suspension and Debarment - Significant Deficiency in Internal Control Over Compliance Recommendation: We recommend the Commission continue with the policies and procedures now established and require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In April 2024, the Commission established a policy requiring documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Name of the contact person responsible for corrective action: Tracie Thomas Planned completion date for corrective action plan: Corrective action was taken April 2024.
2023-003
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: MD-0044 and 2021 Award Period: March 11, 2021 through December 31, 2024, liquidated by December 31, 2026 Type of Finding: Material Weakness in Internal Control Over Compliance, Material Non-Compliance Criteria or Specific Requirement: Per §200.319 and §200.320, all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition. Per §200.320, there are specific circumstances in which noncompetitive procurement can be used. Per §200.320, formal procurement methods must be used on procurements exceeding $250,000. Questioned Costs: Unknown Condition/Context: Two of five vendors tested did not have the proper documentation maintained to support that the non-competitive procurement method used was appropriate under the circumstances. Three of five vendors tested did not follow the appropriate procurement method given the dollar value of expenditures paid to the vendor. Cause: At the time of grant inception, the non-compliance was primarily due to a lack of awareness and training among staff regarding the procurement policy requirements. Effect: The failure to follow proper procurement procedures increases the risk of favoritism, fraud, and inefficient use of resources. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Commission continue to follow the procurement policy and procedures now established and provide comprehensive training to all relevant staff on procurement policies and procedures. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: MD-0044 and 2021 Award Period: March 11, 2021 through December 31, 2024, liquidated by December 31, 2026 Type of Finding: Material Weakness in Internal Control Over Compliance, Material Non-Compliance Criteria or Specific Requirement: Per §200.319 and §200.320, all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition. Per §200.320, there are specific circumstances in which noncompetitive procurement can be used. Per §200.320, formal procurement methods must be used on procurements exceeding $250,000. Questioned Costs: Unknown Condition/Context: Two of five vendors tested did not have the proper documentation maintained to support that the non-competitive procurement method used was appropriate under the circumstances. Three of five vendors tested did not follow the appropriate procurement method given the dollar value of expenditures paid to the vendor. Cause: At the time of grant inception, the non-compliance was primarily due to a lack of awareness and training among staff regarding the procurement policy requirements. Effect: The failure to follow proper procurement procedures increases the risk of favoritism, fraud, and inefficient use of resources. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Commission continue to follow the procurement policy and procedures now established and provide comprehensive training to all relevant staff on procurement policies and procedures. Views of Responsible Officials: Management agrees with the finding.
State and Local Fiscal Recovery Funds– Assistance Listing No. 21.027 Procurement – Material Weakness in Internal Control Over Compliance, Material Non-Compliance Recommendation: We recommend the Commission continue to follow the procurement policy now established and provide comprehensive training to all relevant staff on procurement policies and procedures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In April 2024, the Commission implemented a federal funding procurement policy. The sources of grant funding have expanded extensively since the inception of expanding broadband service to underserved communities. The original primary source of funding was ReConnect, a federal grant from the USDA, and funding subsequently expanded to include the State of Maryland. The Commission received guidance from ReConnect, allowing the Commission to single source vendors for inventory for standardization within the system, both our existing and the new system. The Commission issued purchased orders to stockpile materials under that guidance starting in May 2021 to avoid construction delays due to long lead times experienced throughout the industry. Maryland grants agreements were signed August 2021, July 2022, and June 2023. The use of material procured using the methods allowed by the ReConnect grant had been discussed and agreed upon between the Commission’s Chief Financial Officer (at the time) and the Director of the Department of Housing and Community Development Office of Statewide Broadband; however, approval had not been memorialized in writing. The Commission also has contracts with vendors established under the ReConnect grant following their guidance. The Commission utilizes consistent and established vendors on this project as the project as a whole covers the entire county and some areas overlap or are intertwined. Vendors used are familiar with the entire project. Name of the contact person responsible for corrective action: Tracie Thomas Planned completion date for corrective action plan: Corrective action was taken April 2024.
FAC accepted this audit on March 25, 2024 — management decision was due September 25, 2024.
2023 – 001 Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural eConnectivity Pilot Program Assistance Listing Number: 10.752 Federal Award Identification Number and Year: MD 1701-A64, 2020 Award Period: July 1, 2020 – July 1, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Per 2CFR § 200.303(a), nonfederal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). COSO/Internal Control Framework defines control activities as “policies and procedures that help ensure management’s directives are carried out.” Management review controls are defined as, “the activities of a person, different than the preparer, through analyzing and performing oversight of activities performed, and is an integral part of any internal control structure.” Questioned Costs: None Condition/Context: The Commission did not maintain evidence of the approval of inventory expenditures charged to the grant for the first eight months of fiscal year ended June 30, 2023. Cause: The Commission did not have sufficient policies and procedures over internal controls to maintain evidence of review and approval of inventory expenditures are properly documented until March 2023. Effect: Inventory expenditures may be charged to the grant that are not eligible. Repeat Finding: This is a repeat finding. Recommendation: We recommend the Commission continue with established policies and procedures implemented in March 2023 over internal controls to ensure review and approval of inventory expenditures are properly documented. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2023 – 001 Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural eConnectivity Pilot Program Assistance Listing Number: 10.752 Federal Award Identification Number and Year: MD 1701-A64, 2020 Award Period: July 1, 2020 – July 1, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Per 2CFR § 200.303(a), nonfederal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). COSO/Internal Control Framework defines control activities as “policies and procedures that help ensure management’s directives are carried out.” Management review controls are defined as, “the activities of a person, different than the preparer, through analyzing and performing oversight of activities performed, and is an integral part of any internal control structure.” Questioned Costs: None Condition/Context: The Commission did not maintain evidence of the approval of inventory expenditures charged to the grant for the first eight months of fiscal year ended June 30, 2023. Cause: The Commission did not have sufficient policies and procedures over internal controls to maintain evidence of review and approval of inventory expenditures are properly documented until March 2023. Effect: Inventory expenditures may be charged to the grant that are not eligible. Repeat Finding: This is a repeat finding. Recommendation: We recommend the Commission continue with established policies and procedures implemented in March 2023 over internal controls to ensure review and approval of inventory expenditures are properly documented. Views of Responsible Officials: Management agrees with the finding.
2023-001 ReConnect Program: Rural Assistance – Assistance Listing No. 10.752 Recommendation: We recommend the Commission continue with established policies and procedures implemented in March 2023 over internal controls to ensure review and approval of inventory expenditures are properly documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In July 2022, EUC implemented a process in which the Supervisor of Velocity Plant Operations reviews material requisitions before the paper requisitions move to Accounting for entry into the accounting system. In March of 2023, EUC implemented the requirement for material requisitions to be initialed in order to document the review process. In May 2023, EUC moved to an electronic material requisition process which does not allow material requisitions to be available for Accounting to enter until they have been approved by a designated approver. All costs are additionally reviewed by the Senior Staff Accountant and the Chief Financial Officer before being submitted for reimbursement to the USDA. Name of the contact person responsible for corrective action: Steve J. Ochse Planned completion date for corrective action plan: Corrective action was taken March 2023.
2022-001
2023 – 002 Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural eConnectivity Pilot Program Assistance Listing Number: 10.752 Federal Award Identification Number and Year: MD 1701-A64, 2020 Award Period: July 1, 2020 – July 1, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: When a nonfederal 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. Questioned Costs: None Condition/Context: One of five vendors tested did not have proper documentation maintained to support suspension and debarment verification was performed prior to them being paid with federal funds. Per SAM.gov, there was no history of the vendor being suspended or debarred. Cause: The Commission’s policies and procedures did not require documentation be maintained to verify vendors are not suspended or debarred prior to paying with Federal grant funds. Effect: The Commission could make a disbursement to a vendor that is suspended or debarred. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Commission review its policies and procedures to require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2023 – 002 Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural eConnectivity Pilot Program Assistance Listing Number: 10.752 Federal Award Identification Number and Year: MD 1701-A64, 2020 Award Period: July 1, 2020 – July 1, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: When a nonfederal 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. Questioned Costs: None Condition/Context: One of five vendors tested did not have proper documentation maintained to support suspension and debarment verification was performed prior to them being paid with federal funds. Per SAM.gov, there was no history of the vendor being suspended or debarred. Cause: The Commission’s policies and procedures did not require documentation be maintained to verify vendors are not suspended or debarred prior to paying with Federal grant funds. Effect: The Commission could make a disbursement to a vendor that is suspended or debarred. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Commission review its policies and procedures to require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Views of Responsible Officials: Management agrees with the finding.
2023-002 ReConnect Program: Rural Assistance – Assistance Listing No. 10.752 Recommendation: We recommend the Commission review its policies and procedures to require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: EUC will expand the current suspension and debarment policy to also include purchases outside of construction contracts. The Purchase Order for this audit finding transaction was issued in April 2022. Name of the contact person responsible for corrective action: Steve J. Ochse Planned completion date for corrective action plan: April 30, 2023
2023 – 003 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: MD-0044 and 2021 Award Period: March 11, 2021 through December 31, 2024, liquidated by December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the non-Federal 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. Questioned Costs: None Condition/Context: Four of five vendors tested did not have proper documentation maintained to support suspension and debarment verification was performed prior to them being paid with federal funds. Per SAM.gov, there was no history of the vendor being suspended or debarred. Cause: The Commission’s policies and procedures did not require documentation be maintained to verify vendors are not suspended or debarred prior to paying with Federal grant funds. Effect: The Commission could make a disbursement to a vendor that is suspended or debarred. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Commission review its policies and procedures to require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2023 – 003 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: MD-0044 and 2021 Award Period: March 11, 2021 through December 31, 2024, liquidated by December 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the non-Federal 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. Questioned Costs: None Condition/Context: Four of five vendors tested did not have proper documentation maintained to support suspension and debarment verification was performed prior to them being paid with federal funds. Per SAM.gov, there was no history of the vendor being suspended or debarred. Cause: The Commission’s policies and procedures did not require documentation be maintained to verify vendors are not suspended or debarred prior to paying with Federal grant funds. Effect: The Commission could make a disbursement to a vendor that is suspended or debarred. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Commission review its policies and procedures to require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Views of Responsible Officials: Management agrees with the finding.
2023-003 Coronavirus State and Local Fisal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend the Commission review its policies and procedures to require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: EUC will expand the current suspension and debarment policy to also include purchases outside of construction contracts. Name of the contact person responsible for corrective action: Steve J. Ochse Planned completion date for corrective action plan: April 30, 2023
FAC accepted this audit on March 28, 2023 — management decision was due September 28, 2023.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural eConnectivity Pilot Program Assistance Listing Number: 10.752 Federal Award Identification Number and Year: MD 1701-A64, 2020 Award Period: July 1, 2020 ? July 1, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2CFR ? 200.318(a), non-Federal entities must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. Questioned Costs: None Condition/Context: The Commission?s procurement policy for federal expenditures is not in accordance with ?? 200.317 through 200.327. Cause/Effect: The Commission does not have sufficient documented policies and procedures over procurement to ensure federal procurement requirements are met. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Commission establish and document procurement policies and procedures in conformity with the Federal requirements ?? 200.317 through 200.327. Views of responsible officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural eConnectivity Pilot Program Assistance Listing Number: 10.752 Federal Award Identification Number and Year: MD 1701-A64, 2020 Award Period: July 1, 2020 ? July 1, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2CFR ? 200.318(a), non-Federal entities must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. Questioned Costs: None Condition/Context: The Commission?s procurement policy for federal expenditures is not in accordance with ?? 200.317 through 200.327. Cause/Effect: The Commission does not have sufficient documented policies and procedures over procurement to ensure federal procurement requirements are met. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Commission establish and document procurement policies and procedures in conformity with the Federal requirements ?? 200.317 through 200.327. Views of responsible officials: Management agrees with the finding.
Rural eConnectivity Pilot Program ? Assistance Listing No. 10.752 Recommendation: We recommend the Commission establish and document procurement policies and procedures in conformity with the Federal requirements ?? 200.317 through 200.327. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Commission will adopt a written procurement policy in accordance with the federal requirements. Since the inception of the Rural eConnectivity program, the Commission has followed the Town of Easton Charter Article IV, Section 2(e) when contracting with third party vendors. The Commission now recognizes compliance with the Charter does not satisfy the necessity for a separate procurement policy to fulfill federal requirements. Name of the contact person responsible for corrective action: Steve J. Ochse Planned completion date for corrective action plan: April 30, 2023
Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural eConnectivity Pilot Program Assistance Listing Number: 10.752 Federal Award Identification Number and Year: MD 1701-A64, 2020 Award Period: July 1, 2020 ? July 1, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2CFR ? 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). COSO/Internal Control Framework defines control activities as ?policies and procedures that help ensure management?s directives are carried out.? Management review controls are defined as, ?the activities of a person, different than the preparer, through analyzing and performing oversight of activities performed, and is an integral part of any internal control structure.? Questioned Costs: None Condition/Context: The Commission did not have a documented review/ approval process in place for equipment and inventory expenditures charged to the grant for the fiscal year ended June 30, 2022. In addition, the Commission did not maintain evidence of the approval of equipment and inventory expenditures charged to the grant. Cause: The Commission does not have sufficient policies and procedures over internal controls to ensure review and approval of grant expenditures are properly documented. Effect: Expenditures may be charged to the grant that are not eligible. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Commission formalize policies and procedures over internal controls to ensure review and approval of equipment and inventory expenditures are properly documented. Views of responsible officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural eConnectivity Pilot Program Assistance Listing Number: 10.752 Federal Award Identification Number and Year: MD 1701-A64, 2020 Award Period: July 1, 2020 ? July 1, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2CFR ? 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). COSO/Internal Control Framework defines control activities as ?policies and procedures that help ensure management?s directives are carried out.? Management review controls are defined as, ?the activities of a person, different than the preparer, through analyzing and performing oversight of activities performed, and is an integral part of any internal control structure.? Questioned Costs: None Condition/Context: The Commission did not have a documented review/ approval process in place for equipment and inventory expenditures charged to the grant for the fiscal year ended June 30, 2022. In addition, the Commission did not maintain evidence of the approval of equipment and inventory expenditures charged to the grant. Cause: The Commission does not have sufficient policies and procedures over internal controls to ensure review and approval of grant expenditures are properly documented. Effect: Expenditures may be charged to the grant that are not eligible. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Commission formalize policies and procedures over internal controls to ensure review and approval of equipment and inventory expenditures are properly documented. Views of responsible officials: Management agrees with the finding.
Rural eConnectivity Pilot Program ? Assistance Listing No. 10.752 Recommendation: We recommend the Commission formalize policies and procedures over internal controls to ensure review and approval of equipment and inventory expenditures are properly documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The review of inventory requisitions will be denoted with the reviewer?s initials. The monthly equipment charges will be provided to the Supervisor of Velocity Plant Operations for review and his approval confirmed via email. Since the inception of the Rural eConnectivity program, the Commission has worked closely with representatives from the USDA to ensure compliance with the USDA?s accounting and reporting requirements. Inventory requisitions are completed by field crew and warehouse personnel, reviewed, and approved by the Supervisor of Velocity Plant Operations who reviews each and files in a binder. There is a final cursory reasonableness review by the Senior Staff Accountant. During the preparation of the USDA?s Financial Requirement Statement for reimbursement purposes, the Senior Staff Accountant and CFO review all invoices and material requisitions for proper coding. This review did not include physical signoff during the period tested. Name of the contact person responsible for corrective action: Steve J. Ochse Planned completion date for corrective action plan: April 30, 2023
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