Carter County, Oklahoma

Finding 2021-003 ? Lack of County-Wide Internal Controls Over Major Federal Programs ?COVID-19 Coronavirus Relief FundPASS-THROUGH GRANTOR: Oklahoma Office of Management and Enterprise ServicesFEDERAL AGENCY: U.S. Department of TreasuryASSISTANCE LISTING: 21.019FEDERAL PROGRAM NAME: COVID-19 Coronavirus Relief FundFEDERAL AWARD YEAR: 2021CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; and Period ofPerformanceQUESTIONED COSTS: $-0-Condition: County-wide internal controls regarding Control Environment, Risk Assessment,Information and Communication, and Monitoring have not been designed.Cause of Condition: Policies and procedures have not been designed and implemented to ensure theCounty complies with grant requirements.Effect of Condition: This condition could result in noncompliance to grant requirements and loss offederal funds.Recommendation: OSAI recommends the County implement a system of internal controls to ensurecompliance with grant requirements.Management Response:Chairman of the Board of County Commissioners: We will work to implement a Risk Assessment plan. Wewill implement controls to help make sure we are in compliance with all grant requirements andfederal funds are expended in accordance with grant agreements and in a timely manner. We willensure employees have the current and correct compliance supplement to work from.Criteria: The GAO Standards ? Section 1 ? Fundamental Concepts of Internal Control ? OV1.01 statesin part:Definition of Internal ControlInternal control is a process effected by an entity?s oversight body, management, and otherpersonnel that provides reasonable assurance that the objectives of an entity will beachieved.Additionally, GAO Standards ? Section 2 ? Establishing an Effective Internal Control System ?OV2.04states in part:Components, Principles, and AttributesControl Environment ? The foundation for an internal control system. It provides the discipline andstructure to help an entity achieve its objectives.Risk Assessment ? Assesses the risks facing the entity as it seeks to achieve its objectives. Thisassessment provides the basis for developing appropriate risk responses.Information and Communication ? The quality information management and personnel communicate anduse to support the internal control system.Monitoring ? Activities management establishes and operates to assess the quality ofperformance over time and promptly resolve the findings of audits and other reviews.

Finding 2021-004 ? Lack of Internal Controls Over Major Federal Programs ? COVID-19Coronavirus Relief FundPASS-THROUGH GRANTOR: Oklahoma Office of Management and Enterprise ServicesFEDERAL AGENCY: U.S. Department of TreasuryASSISTANCE LISTING: 21.019FEDERAL PROGRAM NAME: COVID-19 Coronavirus Relief FundFEDERAL AWARD YEAR: 2021CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; and Period ofPerformanceQUESTIONED COSTS: $-0-Condition: During the process of documenting the County?s internal controls regarding federaldisbursements, we noted that the County has not established procedures to ensure compliance withthe following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/CostPrinciples; and Period of Performance.Cause of Condition: Policies and procedures have not been designed and implemented to ensurefederal expenditures are made in accordance with federal compliance requirements.Effect of Condition: This condition could result in noncompliance to grant requirements and couldlead to a loss of federal funds to the County.Recommendation: OSAI recommends the County gain an understanding of requirements for theseprograms and implement internal control procedures to ensure compliance with requirements.Management Response:Chairman of the Board of County Commissioners: The Board of County Commissioners will work with allCounty Officials to go over all grants and federal monies that the County receives to ensure thatproper internal controls are implemented.Criteria: OMB 2 CFR 200, Subpart D. ?_ .303(a) reads as follows: Subpart D-Post Federal AwardRequirements?200.303 Internal Controls The non-Federal entity must:Establish and maintain effective internal control over the Federal award that provides reasonableassurance that the non-Federal entity is managing the Federal award in compliance with Federalstatutes, regulations, and the terms and conditions of the Federal award. These internal controlsshould 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 IntegratedFramework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Further, accountability and stewardship should be overall goals in management's accounting offederal funds. Internal controls should be designed to monitor compliance with laws and regulationspertaining togrant contracts.