Kay CountyLocal Government

Lack of County-Wide Controls Over Major Program ? Highway Planning and Construction PASS-THROUGH GRANTOR: Bureau of Indian Affairs - BIA FEDERAL AGENCY: U.S. Department of Transportation CFDA NO: 20.205 FEDERAL PROGRAM NAME: Highway Planning and Construction FEDERAL AWARD NUMBER: A15AC00117, A17AC00043 and A19AC00027 FEDERAL AWARD YEAR: 2020 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Matching; Period of Performance; Procurement and Suspension and Debarment, and Special Tests and Provisions. QUESTIONED COSTS: $-0- Condition: County-wide 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 the County is in compliance with grant requirements. Effect of Condition: This condition could result in noncompliance to grant requirements. Recommendation: OSAI recommends that the County implement a system of internal controls to ensure compliance with grant requirements. Management Response: Chairman, Board of County Commissioners: The County will work to implement a risk assessment plan during our internal control meetings to help make sure we are in compliance with all grant requirements. Criteria: GAO Standards ? Section 1 ?Fundamental Concepts of Internal Control - OV1.01 states in part: Definition of Internal Control Internal control is a process effected by an entity?s oversight body, management, and other personnel that provides reasonable assurance that the objectives of an entity will be achieved. Additionally, GAO Standards ? Section 2 ? Establishing an Effective Internal Control System ? OV2.04 states in part: Components, Principles, and Attributes Control Environment - The foundation for an internal control system. It provides the discipline and structure to help an entity achieve its objectives. Risk Assessment - Assesses the risks facing the entity as it seeks to achieve its objectives. This assessment provides the basis for developing appropriate risk responses. Information and Communication - The quality information management and personnel communicate and use to support the internal control system. Monitoring - Activities management establishes and operates to assess the quality of performance over time and promptly resolve the findings of audits and other reviews.

Lack of Internal Controls Over Major Federal Program ? Highway Planning and Construction PASS-THROUGH GRANTOR: Bureau of Indian Affairs FEDERAL AGENCY: U.S. Department of Transportation CFDA NO: 20.205 FEDERAL PROGRAM NAME: Highway Planning and Construction FEDERAL AWARD NUMBER: A15AC00117, A17AC00043 and A19AC00027 FEDERAL AWARD YEAR: 2020 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Matching; Period of Performance; Procurement and Suspension and Debarment, and Special Tests and Provisions. QUESTIONED COSTS: $-0- Condition: During the process of documenting the County?s internal controls regarding federal disbursements, we noted that Kay County has not established procedures to ensure compliance with the following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Matching; Period of Performance; Procurement and Suspension and Debarment, and Special Tests and Provisions. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with federal compliance requirements. Effect of Condition: This condition could result in noncompliance to grant requirements and loss of federal funds to the County. Recommendation: OSAI recommends the County implement a system of internal controls to ensure compliance with grant requirements. Management Response: Chairman, Board of County Commissioners: Kay County officials will implement procedures to ensure federal expenditures are made in accordance with federal compliance requirements. Criteria: GAO Standards ? Section 2 ? Establishing an Effective Internal Control System ? OV2.23 states in part: Objectives of an Entity ? Compliance Objectives Management conducts activities in accordance with applicable laws and regulations. As part of specifying compliance objectives, the entity determines which laws and regulations apply to the entity. Management is expected to set objectives that incorporate these requirements. 2 CFR ? 200.303(a) Internal Controls reads as follows: 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).

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