Collier County

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Planning and Construction Assistance Listing Number: 20.205 Federal Award Identification Number and Year: Various Award Period: Various Type of Finding: Material Weakness in Internal Control over Compliance; Material Noncompliance (Modified Opinion) Criteria or specific requirement: Under 2 CFR 200.313 equipment acquired under a Federal award must be properly managed and proper records must be maintained. These records must contain information pertaining to Federal awards including description of property, serial number or other identification number, source of funding, title, acquisition date and cost of property, condition, ultimate disposition date including disposal, sales price and inventory. A physical inventory of the property must be taken and reconciled at least every two years, control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of property, adequate maintenance procedures must be developed to keep the property in good conditions. Per 2 CFR Section 200.303(a) The non-Federal entity must (a) 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). Condition: The County did not maintain accurate and updated equipment inventory listings for equipment purchased with Federal funds in accordance with 2 CFR 200.313. Questioned costs: None Context: The County’s equipment inventory listing of equipment purchased with grant funds was not maintained in a manner that complied with 2 CFR 200.313 during the year. An inventory listing that complied with 2 CFR 200.313 was prepared once it was requested during the audit. Additionally, for one of eight equipment items selected for testing from the inventory listing, the equipment serial number did not agree with the equipment inventory listing for that equipment’s location. Cause: The County did not have formal policies and procedures in place to manage and maintain equipment inventor records in compliance with 2 CFR 200.313. Effect: The County was not in compliance with the equipment compliance requirements of the program. Repeat Finding: No Recommendation: We recommend the County expand upon their capital asset inventory policies and procedures that are used for financial statement purposes to ensure that all equipment purchased with Federal funds are properly managed and maintained throughout the year to ensure all information, including the serial number and equipment location, is accurate and updated. We also recommend that the program personnel responsible for equipment records certify accuracy of the equipment records throughout the year. Views of responsible officials: Management agrees with the finding. See corrective action plan.

Federal Agency: U.S. Department of the Transportation Federal Program Name: National Infrastructure Investments Assistance Listing Number: 20.933 Federal Award Identification Number and Year: 693JJ32040007 - 2020 Award Period: 08/03/2020 – 10/31/2024 Type of Finding: Material Weakness in Internal Control over Compliance; Material Noncompliance (Modified Opinion) Criteria or specific requirement: Under Davis-Bacon Act - 40 U.S.C. §§ 3141, et seq., as applicable under 23 U.S.C. 113, prevailing wage requirements each contractor must submit weekly certified payrolls to the contracting agency or entity certified payrolls providing information for each covered worker. Each certified payroll must be accompanied by a "Statement of Compliance" certifying compliance with applicable requirements. Per 2 CFR Section 200.303(a) the non-Federal entity must (a) 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). Condition: The County did not obtain, maintain, or review certified payrolls as required for special provisions Davis Bacon Act for all vendors. Questioned costs: None Context: For two out of the eight payrolls selected for testing, the County did not properly obtain and review certified payrolls provided by subcontractor. The certifications were subsequently collected and reviewed when they were selected for audit testing. Cause: The County did not follow its policies, procedures and internal controls related to obtaining and reviewing certified payrolls from vendors. Effect: The County was not in compliance with the special provision compliance requirements of the program. Repeat Finding: No Recommendation: We recommend the County to implement a process and to update its policies and procedures to ensure that all certified payrolls are properly verified and maintained accurately through grant award period and beyond. Views of responsible officials: Management agrees with the finding. See corrective action plan.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: CDBG – Entitlement Grants Cluster Assistance Listing Number: 14.218 Federal Award Identification Number and Year: Various Award Period: Various Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matter Criteria or specific requirement: Under reporting for Federal Funding Accountability and Transparency Act (FFATA) requires awardees such as prime contractors and subcontractors to file a FFATA subaward report by the end of the month following the month in which the prime contractor awards or prime grant recipient is awarded any subcontract or grant greater than $30,000. Per 2 CFR Section 200.303(a) the non-Federal entity must (a) 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). Condition: The County did submit FFATA reports after grant award or grant award modifications were made by the dates required. Questioned costs: None Context: For three out of the five FFATA reports selected for testing, the County submitted reports after the due date. Cause: The County’s internal controls did not prevent or detect the noncompliance. Effect: The County was not in compliance with the reporting compliance requirements of the program. Repeat Finding: No Recommendation: We recommend the County strengthen policies and procedures to ensure that reporting due dates are adhered to as required by the Federal regulations and that internal processes mirror the requirements of the Federal regulations. Views of responsible officials: Management agrees with the finding. See corrective action plan.

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