TOWN OF ORANGE PARKLocal Government

Criteria—According to the Coronavirus State and Local Recover Funds (CSLRF) Final Rule, Suspension and Debarment is covered under CFR 200.214 in Subpart C, which is fully applicable under the revenue replacement method. As such, suspension and debarment should be evaluated and documented for all non-payroll expenditures under the program. Condition—During our testing, it was noted that 1 of 3 of the vendor selections tested for this program did not have suspension and debarment evaluated or documented prior to the purchase. In addition, there was no formal control policy for the Town to evaluate and document suspension and debarment for expenditures in this program. Cause—The Town was unaware of this requirement applied to CSLRF funding under the revenue replacement method. Effect—In this case, there is no indication that the vendor in question was actually suspended or debarred. However, by not evaluating suspension and debarment for the expenditures of this program, expenditures could be made that do not comply with the program requirements for suspension and debarment. Recommendation—We recommend that suspension and debarment be evaluated and documented for all expenditures made for this program and that a formal control policy for suspension and debarment be considered for such purchases.

Criteria - According to the Coronavirus State and Local Recovery Funds (CSLRF) Final Rule, Suspension and Debarment is covered under CFR 200.214 in Subpart C, which is fully applicable under the revenue replacement method. As such, suspension and debarment should be evaluated and documented for all non-payroll expenditures under the program. Condition - During our testing, it was noted that 1 of 5 of the vendor selections tested for this program did not have suspension and debarment evaluated or documented prior to the purchase. In addition, there was no formal control policy for the Town to evaluate and document suspension and debarment for expenditures in this program. Cause - The Town was unaware of this requirement applied to CSLRF funding under the revenue replacement method. Effect - In this case, there is no indication that the vendor in question was actually suspended or debarred. However, by not evaluating suspension and debarment for the expenditures of this program, expenditures could be made that do not comply with the program requirements for suspension and debarment. Recommendation - We recommend that suspension and debarment be evaluated and documented for all expenditures made for this program and that a formal control policy for suspension and debarment be considered for such purchases.

2019-01 - Internal Control Over Matching Costs - Condition? As part of the conditions of the CFDA: 10.923 grant the Town is required to provide a match of 25% of the construction costs in the form of cash, in-kind construction services, or a combination of both. During our testing of the Town?s in-kind labor and equipment usage costs we noted that 5 of the 40 items selected for testing did not have sufficient supporting records. Although employee time charged to the grant had timesheets that supported they worked on the days in question, sufficient detail was not maintained to support that they worked specifically on the grant funded project. There were also insufficient records documenting equipment used on the project to support in-kind equipment usage costs charged to grant. Our testing indicated that these items were isolated to the month of December 2018 which was near the beginning of when the in-kind construction services began. It appears process and documentation were improved after that point and were sufficient to support charging of time and equipment costs to the grant. Effect?The lack of supporting documentation resulted in questioned costs of $2,423 for the five items selected in our testing. As documentation appears to have been sufficient after December 2018, the total projected questioned costs for the month of December 2018 are estimated to be $14,701.Recommendation?We recommend that the Town evaluate the impact of the finding on the reimbursement requested, and adjust the reimbursement request to meet the required 25% match, possibly substituting other eligible matching costs incurred.