Marshall County

Finding 2025-010 – Lack of County-Wide Internal Controls Over Major Federal Program –Coronavirus State and Local Fiscal Recovery Funds PASS THROUGH GRANTOR: Direct Grant FEDERAL AGENCY: U.S. Department of Treasury ASSISTANCE LISTING: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds FEDERAL AWARD YEAR: 2021 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Procurement and Suspension and Debarment; Reporting QUESTIONED COSTS: $-0- Condition: Through the process of gaining an understanding of the County’s internal control structure, it was noted that 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 the County complies with grant requirements. Effect of Condition: Without an adequate system of county-wide controls, there is a greater risk of a breakdown in control activities which could result in unrecorded transactions, undetected errors, or misappropriation of funds. Further, this condition could result in noncompliance with grant requirements and a loss of federal funds. Recommendation: OSAI recommends that the County design and implement a system of internal control procedures to ensure compliance with grant requirements. This documentation should outline the importance of internal controls, the risk that the County has identified, the control activities established to address the risk, the steps taken to properly communicate pertinent information in a timely manner and the methodology to monitor the quality of performance over time. These procedures should be written policies and procedures and could be included in the County’s policies and procedures handbook. Management Response: Chairman of the Board of County Commissioners: The Board of County Commissioners will work toward assessing and identifying risks to design written county-wide controls. Criteria: The 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.

Finding 2025-011 – Lack of Internal Controls Over Major Federal Program – Coronavirus State and Local Fiscal Recovery Funds PASS THROUGH GRANTOR: Direct Grant FEDERAL AGENCY: U.S. Department of Treasury ASSISTANCE LISTING: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds FEDERAL AWARD YEAR: 2021 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Procurement and Suspension and Debarment; Reporting QUESTIONED COSTS: $-0- Condition: During the process of documenting the County’s internal controls regarding federal disbursements, we noted the County has not established procedures to ensure compliance with the following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Procurement and Suspension and Debarment; Reporting. 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 with grant requirements and could lead to a loss of federal funds to the County. Recommendation: OSAI recommends the County gain an understanding of requirements for this program 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 all County Officials to go over all grants and federal monies that Comanche County receives to ensure that proper internal controls are implemented. Criteria: 2 CFR § 200.303 Internal Controls (a) reads as follows: The non-Federal entity must: 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). Further, accountability and stewardship should be overall goals in management's accounting of federal funds. Internal controls should be designed to monitor compliance with laws and regulations pertaining to grant contracts.

Finding 2021-010 Lack of County-Wide Internal Controls Over Major Federal Program ? Coronavirus Relief FundPASS-THROUGH GRANTOR: Oklahoma Office of Management and Enterprise Services; and Oklahoma Department of Emergency Managementand Homeland SecurityFEDERAL AGENCY: U.S. Department of TreasuryASSISTANCE LISTING: 21.019FEDERAL PROGRAM NAME: Coronavirus Relief FundFEDERAL AWARD YEAR: 2020CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of PerformanceQUESTIONED COSTS: $-0-Condition: Through the process of gaining an understanding of the County?s internal controlstructure for federal programs, it was noted that county-wide internal controls regarding ControlEnvironment, 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 is in compliance with grant requirements.Effect of Condition: This condition could result in noncompliance with grant requirements.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 be achieved.Additionally, GAO Standards ? Section 2 ? Establishing an Effective Internal Control System ?OV2.04 states 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 of performanceover time and promptly resolve the findings of audits and other reviews.Finding

Finding 2021-011 Lack of Internal Controls Over Major Federal Program ? Coronavirus Relief FundPASS-THROUGH GRANTOR: Oklahoma Office of Management and Enterprise Services; and Oklahoma Department of Emergency Managementand Homeland SecurityFEDERAL AGENCY: U.S. Department of TreasuryASSISTANCE LISTING: 21.019FEDERAL PROGRAM NAME: Coronavirus Relief FundFEDERAL AWARD YEAR: 2020CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of PerformanceQUESTIONED COSTS: $-0-Condition: During the process of documenting the County?s internal controls regarding federaldisbursements, we noted that policies and procedures have not been established to ensure compliancewith the following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/CostPrinciples; and Period of Performance of Federal Funds.Cause of Condition: Policies and procedures have not been designed and implemented to ensurefederal expenditures are made in accordance with federal compliance requirements.Condition: This condition could result in noncompliance to grant requirements and loss of federalfunds to the County.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: The Board of County Commissioners will implementprocedures to ensure federal funds are expended in accordance with grant requirements.Criteria: OMB 2 CFR 200, Subpart D. ?_ .303(a) reads as follows:Subpart D-Post Federal Award Requirements?200.303 Internal ControlsThe non-Federal entity must:Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in ?Standards forInternal Control in the Federal Government? issued by the Comptroller General of theUnited States or the ?Internal Control Integrated Framework?, issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO).Further, accountability and stewardship should be overall goals in management's accounting of federalfunds. Internal controls should be designed to monitor compliance with laws and regulations pertaining togrant contracts.