Junaluska Sanitary District

Criteria: Uniform Guidance (CFR.24.102) requires local governmental entities to follow specific negotiation practices when acquiring real property, including permanent easements. Real property acquisition practices under the Uniform Guidance includes establishing and making an offer of just compensation. Real property acquisition policies apply to all real property purchased as part of a federal project, even if the acquisition costs are not paid from a federal funding source. Condition: The District obtained a permanent easement for the Water Infrastructure project without obtaining an appraisal or a waiver valuation, documenting the amount they believed to be just compensation, making an initial written purchase offer with a written statement of the basis for the offer of just compensation or making payment prior to obtaining the easement.

II. Federal Award Findings and Questioned Costs Name of Contact Person: Josh Nickol, General Manager/Finance Officer Corrective Action: Junaluska Sanitary District will ensure to fully understand and follow all applicable sections of the Uniform Guidance policy adopted by the board on December 10, 2020 as it relates to capital projects. When specific property easements occur that are not clearly understood or evident in the policy, we will contact state and federal funding sources as well as accounting and legal professionals for further guidance. Proposed Completion Date: The corrective action plan will be implemented immediately.

Although Junaluska Sanitary District was found to be in compliance with requirements of federal and state procurement policies, their written procurement policies do not include all applicable sections required by Uniform Guidance.

Policies and procedures are being revised to include all applicable sections of both federal and state regulations. Proposed completion date is December 31, 2020.