EIN: 736006404
UEI: MWQMMCC3ZMJ5
Audited by: Oklahoma State Auditor & Inspector
Oversight agency: 21 [Department of the Treasury]
Data as of August 27, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 11, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by August 11, 2025 (382 days ago).
What is a management decision? →Upon inquiry, review, and testwork of 100% of major program expenditures, the following exceptions were noted: • The County was reimbursed $477,097 for payroll expenditures which were determined to be unallowable costs to mitigate or prevent the spread of COVID-19 as required by the grant agreement. Cause of Condition: Policies and procedures have not been designed and implemented to ensure that the compliance with applicable grant requirements. Effect of Condition: These conditions resulted in noncompliance with federal grant requirements. This could hinder the County from receiving future federal funding and could result in the repayment of grant funds to the grantor agency. Recommendation: OSAI recommends the County gain an understanding of requirements for this program and design and implement policies and procedures to ensure compliance with all applicable grant requirements. Management Response: District 1 County Commissioner: Ottawa County has designed and implemented policies and procedures to ensure compliance with all applicable grant requirements. District 2 County Commissioner: I was not in office at this time. This was a one-time grant. District 3 County Commissioner: I did not take office until January 2023; however, District 3 will work to better understand all requirements of federal programs and implement better procedures to follow all guidelines and ensure compliance. Criteria: 2 CFR § 200.403 - Factors affecting allowability costs states in relevant part, Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. 42 United States Code § 801 – Coronavirus relief fund Section 801(d) requires the States, Tribal governments, or units of local government use the funds received to cover only those costs that (1) are necessary expenditures incurred due to the public health emergency with respect to the Coronavirus Disease 2019 (COVID-19); (2) were not accounted for in the budget most recently approved as of March 27, 2020, for the State or government; and (3) were incurred during the period that begins on March 1, 2020, and ends on December 30, 2020.
Show full finding ▾Hide full finding ▴PASS-THROUGH GRANTOR: Oklahoma Department of Emergency Management and Oklahoma Office and Management and Enterprise Services FEDERAL AGENCY: U.S. Department of Treasury ASSISTANCE LISTING: 21.019 FEDERAL PROGRAM NAME: Coronavirus Relief Fund FEDERAL AWARD NUMBER: Oklahoma CARES PPE; 4530-DR-OK; SA-2242 FEDERAL AWARD YEAR: 2021 CONTROL CATEGORY: Activities Allowed or Unallowed and Allowable Costs/Costs Principles QUESTIONED COSTS: $477,097 Condition: Upon inquiry, review, and testwork of 100% of major program expenditures, the following exceptions were noted: • The County was reimbursed $477,097 for payroll expenditures which were determined to be unallowable costs to mitigate or prevent the spread of COVID-19 as required by the grant agreement. Cause of Condition: Policies and procedures have not been designed and implemented to ensure that the compliance with applicable grant requirements. Effect of Condition: These conditions resulted in noncompliance with federal grant requirements. This could hinder the County from receiving future federal funding and could result in the repayment of grant funds to the grantor agency. Recommendation: OSAI recommends the County gain an understanding of requirements for this program and design and implement policies and procedures to ensure compliance with all applicable grant requirements. Management Response: District 1 County Commissioner: Ottawa County has designed and implemented policies and procedures to ensure compliance with all applicable grant requirements. District 2 County Commissioner: I was not in office at this time. This was a one-time grant. District 3 County Commissioner: I did not take office until January 2023; however, District 3 will work to better understand all requirements of federal programs and implement better procedures to follow all guidelines and ensure compliance. Criteria: 2 CFR § 200.403 - Factors affecting allowability costs states in relevant part, Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. 42 United States Code § 801 – Coronavirus relief fund Section 801(d) requires the States, Tribal governments, or units of local government use the funds received to cover only those costs that (1) are necessary expenditures incurred due to the public health emergency with respect to the Coronavirus Disease 2019 (COVID-19); (2) were not accounted for in the budget most recently approved as of March 27, 2020, for the State or government; and (3) were incurred during the period that begins on March 1, 2020, and ends on December 30, 2020.
The county will work to design and implement a system of internal controls to ensure compliance with all applicable grant requirements.
Through the process of gaining an understanding of the County’s internal control structure for federal programs, 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 is in compliance with grant requirements. Effect of Condition: Without an adequate system of county-wide controls, there is greater risk of a breakdown in control activities which could result in unrecorded transactions, undetected errors, misappropriation of funds, and noncompliance with grant requirements. Recommendation: OSAI recommends that the County implement a system of internal controls to ensure compliance with grant requirements. Management Response: District 1 County Commissioner: Ottawa County has implemented a system of internal controls to ensure compliance with the grant requirements. District 2 County Commissioner: I was not in office at this time; however, I will work to implement a system of internal controls to ensure compliance with grant requirements. District 3 County Commissioner: I did not take office until January 2023; however, District 3 will work to better understand all grant requirements to ensure compliance. County Clerk: The County Clerk’s office is continuously learning policies and procedures needed to ensure the County’s federal programs have adequate internal controls. The County Clerk’s office will work on getting written internal control policies and procedures in place. 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.
Show full finding ▾Hide full finding ▴PASS-THROUGH GRANTOR: Oklahoma Department of Emergency Management and Oklahoma Office and Management and Enterprise Services FEDERAL AGENCY: U.S. Department of Treasury ASSISTANCE LISTING: 21.019 FEDERAL PROGRAM NAME: Coronavirus Relief Fund FEDERAL AWARD NUMBER: Oklahoma CARES PPE; 4530-DR-OK; SA-2242 FEDERAL AWARD YEAR: 2021 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Costs Principles; and Period of Performance QUESTIONED COSTS: $-0- Condition: Through the process of gaining an understanding of the County’s internal control structure for federal programs, 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 is in compliance with grant requirements. Effect of Condition: Without an adequate system of county-wide controls, there is greater risk of a breakdown in control activities which could result in unrecorded transactions, undetected errors, misappropriation of funds, and noncompliance with grant requirements. Recommendation: OSAI recommends that the County implement a system of internal controls to ensure compliance with grant requirements. Management Response: District 1 County Commissioner: Ottawa County has implemented a system of internal controls to ensure compliance with the grant requirements. District 2 County Commissioner: I was not in office at this time; however, I will work to implement a system of internal controls to ensure compliance with grant requirements. District 3 County Commissioner: I did not take office until January 2023; however, District 3 will work to better understand all grant requirements to ensure compliance. County Clerk: The County Clerk’s office is continuously learning policies and procedures needed to ensure the County’s federal programs have adequate internal controls. The County Clerk’s office will work on getting written internal control policies and procedures in place. 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.
The county will work to design and implement a system of internal controls to ensure compliance with all applicable grant requirements.
During the process of documenting the County’s internal controls regarding federal disbursements, we noted that Ottawa County has not established procedures to ensure compliance with the following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/Costs Principles and Period of Performance. Submissions for reimbursement from the Coronavirus Relief Fund were not reviewed by the BOCC for Activities Allowed/Allowed Costs, or to ensure the expenses were incurred during the allowable period of performance. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with federal grant compliance requirements. Effect of Condition: This condition could result in noncompliance with grant requirements and could lead to the 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 all requirements. Management Response: District 1 County Commissioner: Ottawa County has implemented internal control procedures to ensure compliance with all requirements. District 2 County Commissioner: I was not in office at this time; however, I will work to gain an understanding of grant requirements and implement internal controls to ensure compliance with those requirements. District 3 County Commissioner: I did not take office until January 2023; however, District 3 will work to better understand all requirements of federal programs and implement better procedures to follow all guidelines to ensure compliance. County Clerk: The County Clerk’s office is continuously learning policies and procedures needed to ensure the County’s federal programs have adequate internal controls. The County Clerk’s office will work on getting written internal control policies and procedures in place. Criteria: 2 CFR § 200.303(a) Internal Controls 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). 2 CFR § 213 states, “Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Additionally, 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.
Show full finding ▾Hide full finding ▴PASS-THROUGH GRANTOR: Oklahoma Department of Emergency Management and Oklahoma Office and Management and Enterprise Services FEDERAL AGENCY: U.S. Department of Treasury ASSISTANCE LISTING: 21.019 FEDERAL PROGRAM NAME: Coronavirus Relief Fund FEDERAL AWARD NUMBER: Oklahoma CARES PPE; 4530-DR-OK; SA-2242 FEDERAL AWARD YEAR: 2021 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Costs Principles; and Period of Performance QUESTIONED COSTS: $-0- Condition: During the process of documenting the County’s internal controls regarding federal disbursements, we noted that Ottawa County has not established procedures to ensure compliance with the following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/Costs Principles and Period of Performance. Submissions for reimbursement from the Coronavirus Relief Fund were not reviewed by the BOCC for Activities Allowed/Allowed Costs, or to ensure the expenses were incurred during the allowable period of performance. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with federal grant compliance requirements. Effect of Condition: This condition could result in noncompliance with grant requirements and could lead to the 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 all requirements. Management Response: District 1 County Commissioner: Ottawa County has implemented internal control procedures to ensure compliance with all requirements. District 2 County Commissioner: I was not in office at this time; however, I will work to gain an understanding of grant requirements and implement internal controls to ensure compliance with those requirements. District 3 County Commissioner: I did not take office until January 2023; however, District 3 will work to better understand all requirements of federal programs and implement better procedures to follow all guidelines to ensure compliance. County Clerk: The County Clerk’s office is continuously learning policies and procedures needed to ensure the County’s federal programs have adequate internal controls. The County Clerk’s office will work on getting written internal control policies and procedures in place. Criteria: 2 CFR § 200.303(a) Internal Controls 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). 2 CFR § 213 states, “Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Additionally, 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.
The county will work to design and implement a system of internal controls to ensure compliance with all applicable grant requirements.
FAC accepted this audit on August 1, 2023 — management decision was due February 1, 2024.
Through the process of gaining an understanding of the County?s internal control structure for federal programs, 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 is in compliance with grant requirements. Effect of Condition: Without an adequate system of county-wide controls, there is greater risk of a breakdown in control activities which could result in unrecorded transactions, undetected errors, misappropriation of funds, and noncompliance with grant requirements. Recommendation: OSAI recommends that the County implement a system of internal controls to ensure compliance with grant requirements. Management Response: District 1 County Commissioner: I will work with other election officials to implement a system of internal controls to ensure compliance with all grant requirements. District 2 County Commissioner: I was not in office in this fiscal year; however, I will work with other elected officials to implement a system of internal controls to ensure compliance with federal grant requirements. District 3 County Commissioner: I did not take office until January 2023; however, District 3 will work to better understand all grant requirements to ensure compliance. County Clerk: We will work with the County Commissioners to implement a system of internal controls to ensure compliance with grant requirements. 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. Furthermore, 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).
Show full finding ▾Hide full finding ▴2020-017 - Lack of County-Wide Controls Over Major Federal Program ? Highway Planning and Construction (Repeat Finding - 2017-020, 2019-020) FEDERAL AGENCY: U.S. Department of Transportation FEDERAL PROGRAM CLUSTER: Highway Planning and Construction Cluster ASSISTANCE LISTING: 20.205 FEDERAL PROGRAM NAME: Highway Planning and Construction FEDERAL AWARD NUMBER: BIA ? A13AC00042-Cayuga Road and A16AC00032-Stateline Road FEDERAL AWARD YEAR: 2017 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Costs Principles; Period of Performance; Procurement and Suspension and Debarment; Special Tests and Provisions. QUESTIONED COSTS: $-0- Condition: Through the process of gaining an understanding of the County?s internal control structure for federal programs, 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 is in compliance with grant requirements. Effect of Condition: Without an adequate system of county-wide controls, there is greater risk of a breakdown in control activities which could result in unrecorded transactions, undetected errors, misappropriation of funds, and noncompliance with grant requirements. Recommendation: OSAI recommends that the County implement a system of internal controls to ensure compliance with grant requirements. Management Response: District 1 County Commissioner: I will work with other election officials to implement a system of internal controls to ensure compliance with all grant requirements. District 2 County Commissioner: I was not in office in this fiscal year; however, I will work with other elected officials to implement a system of internal controls to ensure compliance with federal grant requirements. District 3 County Commissioner: I did not take office until January 2023; however, District 3 will work to better understand all grant requirements to ensure compliance. County Clerk: We will work with the County Commissioners to implement a system of internal controls to ensure compliance with grant requirements. 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. Furthermore, 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).
The County will work to design and implement a system of internal controls to ensure compliance with all applicable grant requirements.
2019-020
During the process of documenting the County?s internal controls regarding federal disbursements, we noted that Ottawa County has not established procedures to ensure compliance with the following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/Costs Principles; Period of Performance; Procurement and Suspension and Debarment; 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 with grant requirements and could lead to the 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 all requirements. Management Response: District 1 County Commissioner: I will work with other elected officials to implement a system of internal controls to ensure compliance with all grant requirements. District 2 County Commissioner: I was not in office at the time of these findings; however, I will work with other elected officials to implement a system of internal controls to ensure compliance with federal grant requirements. District 3 County Commissioner: I did not take office until January 2023; however, District 3 will work to better understand all requirements of federal programs and implement better procedures to follow all guidelines to ensure compliance. County Clerk: We will work with the County Commissioners to ensure compliance with federal grant requirements. Criteria: 2 CFR ? 200.303(a) Internal Controls 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). 2 CFR ? 213 states, ?Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.? Additionally, 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.
Show full finding ▾Hide full finding ▴Finding 2020-018 - Lack of Internal Controls Over Major Federal Program? Highway Planning and Construction (Repeat Finding ? 2017-024, 2019-021) FEDERAL AGENCY: U.S. Department of Transportation FEDERAL PROGRAM CLUSTER: Highway Planning and Construction Cluster ASSISTANCE LISTING: 20.205 FEDERAL PROGRAM NAME: Highway Planning and Construction FEDERAL AWARD NUMBER: BIA ? A13AC00042-Cayuga Road and A16AC00032-Stateline Road FEDERAL AWARD YEAR: 2017 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Costs Principles; Period of Performance; Procurement and Suspension and Debarment; Special Tests and Provisions. QUESTIONED COSTS: $-0- Condition: During the process of documenting the County?s internal controls regarding federal disbursements, we noted that Ottawa County has not established procedures to ensure compliance with the following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/Costs Principles; Period of Performance; Procurement and Suspension and Debarment; 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 with grant requirements and could lead to the 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 all requirements. Management Response: District 1 County Commissioner: I will work with other elected officials to implement a system of internal controls to ensure compliance with all grant requirements. District 2 County Commissioner: I was not in office at the time of these findings; however, I will work with other elected officials to implement a system of internal controls to ensure compliance with federal grant requirements. District 3 County Commissioner: I did not take office until January 2023; however, District 3 will work to better understand all requirements of federal programs and implement better procedures to follow all guidelines to ensure compliance. County Clerk: We will work with the County Commissioners to ensure compliance with federal grant requirements. Criteria: 2 CFR ? 200.303(a) Internal Controls 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). 2 CFR ? 213 states, ?Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.? Additionally, 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.
The County will work to design and implement a system of internal controls to ensure compliance with all applicable grant requirements.
2019-021
Upon inquiry, review, and testwork of fourteen (14) or 100% of major program expenditures, the following exceptions were noted: ? Eight (8) invoices totaling $989,434.94 could not be located. ? In addition to not being supported by an invoice, the County could not provide an approved, signed copy of purchase order 4709. 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 resulted in noncompliance with Federal grant requirements, a qualification of opinion on the County?s compliance for major programs and could lead to the 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 all requirements. Management Response: District 1 County Commissioner: I will work with other elected officials to implement a system of internal controls to ensure compliance with all grant requirements. District 2 County Commissioner: I was not in office during this fiscal year; however, I will work with other elected officials to gain understanding of requirements for this Federal program and to implement internal control procedures to ensure the county is in compliance with all requirements. District 3 County Commissioner: I did not take office until January 2023; however, District 3 will work to better understand all requirements of federal programs and implement better procedures to follow all guidelines and ensure compliance. County Clerk: We will work with all county officials to ensure compliance with federal grant requirements. For the expenditures paid without invoice, we had drawdown documentation and assumed it would work for an invoice. We will make sure that documentation is not used again. Criteria: 2 CFR ? 200.303(a) Internal Controls 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). 2 CFR ? 200.84 Questioned Cost reads as follows: Questioned cost means a cost that is questioned by the auditor because of an audit finding: (a) Which resulted from a violation or possible violation of a statute, regulation, or the terms and conditions of a Federal award, including for fund used to match Federal funds: (b) Where the cost, at the time of the audit, are not supported by adequate documentation: or (c) Where the costs incurred appear unreasonable and do not reflect the actions a prudent person would take in the circumstances. 2 CFR ? 200.318 (a), General procurement standards, reads as follows: The Non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part. Additionally, 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.
Show full finding ▾Hide full finding ▴Finding 2020-019 - Lack of Internal Controls and Noncompliance with Compliance Requirements: A ? Activities Allowed or Unallowed and B ? Allowable Costs/Costs Principles ? Highway Planning and Construction (Repeat Finding - 2019-022) FEDERAL AGENCY: U.S. Department of Transportation FEDERAL PROGRAM CLUSTER: Highway Planning and Construction Cluster ASSISTANCE LISTING: 20.205 FEDERAL PROGRAM NAME: Highway Planning and Construction FEDERAL AWARD NUMBER: BIA ? A13AC00042?Cayuga Road and A16AC00032?Stateline Road FEDERAL AWARD YEAR: 2017 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Costs Principles QUESTIONED COSTS: $989,434.94 Condition: Upon inquiry, review, and testwork of fourteen (14) or 100% of major program expenditures, the following exceptions were noted: ? Eight (8) invoices totaling $989,434.94 could not be located. ? In addition to not being supported by an invoice, the County could not provide an approved, signed copy of purchase order 4709. 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 resulted in noncompliance with Federal grant requirements, a qualification of opinion on the County?s compliance for major programs and could lead to the 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 all requirements. Management Response: District 1 County Commissioner: I will work with other elected officials to implement a system of internal controls to ensure compliance with all grant requirements. District 2 County Commissioner: I was not in office during this fiscal year; however, I will work with other elected officials to gain understanding of requirements for this Federal program and to implement internal control procedures to ensure the county is in compliance with all requirements. District 3 County Commissioner: I did not take office until January 2023; however, District 3 will work to better understand all requirements of federal programs and implement better procedures to follow all guidelines and ensure compliance. County Clerk: We will work with all county officials to ensure compliance with federal grant requirements. For the expenditures paid without invoice, we had drawdown documentation and assumed it would work for an invoice. We will make sure that documentation is not used again. Criteria: 2 CFR ? 200.303(a) Internal Controls 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). 2 CFR ? 200.84 Questioned Cost reads as follows: Questioned cost means a cost that is questioned by the auditor because of an audit finding: (a) Which resulted from a violation or possible violation of a statute, regulation, or the terms and conditions of a Federal award, including for fund used to match Federal funds: (b) Where the cost, at the time of the audit, are not supported by adequate documentation: or (c) Where the costs incurred appear unreasonable and do not reflect the actions a prudent person would take in the circumstances. 2 CFR ? 200.318 (a), General procurement standards, reads as follows: The Non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part. Additionally, 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.
The County will work to design and implement a system to establish and maintain effective internal control over federal awarded funds. This includes compliance with federal statutes, regulations, and terms and conditions of the federal award to meet requirements for this program.
2019-022
FAC accepted this audit on February 14, 2023 — management decision was due August 14, 2023.
Through the process of gaining an understanding of the County?s internal control structure for federal programs, it was noted that county-wide internal controls regarding Control Environment, Risk Assessment, Information and Communication, and Monitoring have not been designed and implemented. 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: Without an adequate system of county-wide controls, there is greater risk of a breakdown in control activities which could result in unrecorded transactions, undetected errors, misappropriation of funds, and noncompliance with grant requirements. Recommendation: OSAI recommends the County implement a system of internal controls to ensure compliance with grant requirements. Management Response: District 1 County Commissioner: I will work with other officials to implement a system of internal controls to ensure compliance with grant requirements. District 2 County Commissioner: I was not in office at the time of these findings; however, I will work with other elected officials to implement a system of internal controls to ensure compliance with federal grant requirements. District 3 County Commissioner: The County will work to design and implement a system of internal controls to ensure compliance with all applicable grant requirements 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.
Show full finding ▾Hide full finding ▴Finding 2019-020 ? Lack of County-Wide Controls Over Major Federal Program ? Highway Planning and Construction (Repeat Finding ? 2017-020) FEDERAL AGENCY: U.S. Department of Transportation ASSISTANCE LISTING: 20.205 FEDERAL PROGRAM NAME: Highway Planning and Construction FEDERAL AWARD NUMBER: BIA ? A13AC00042 and A16AC00032 FEDERAL AWARD YEAR: 2017 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Costs Principles; Period of Performance; Procurement and Suspension and Debarment; Special Tests and Provisions. QUESTIONED COSTS: $-0- Condition: Through the process of gaining an understanding of the County?s internal control structure for federal programs, it was noted that county-wide internal controls regarding Control Environment, Risk Assessment, Information and Communication, and Monitoring have not been designed and implemented. 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: Without an adequate system of county-wide controls, there is greater risk of a breakdown in control activities which could result in unrecorded transactions, undetected errors, misappropriation of funds, and noncompliance with grant requirements. Recommendation: OSAI recommends the County implement a system of internal controls to ensure compliance with grant requirements. Management Response: District 1 County Commissioner: I will work with other officials to implement a system of internal controls to ensure compliance with grant requirements. District 2 County Commissioner: I was not in office at the time of these findings; however, I will work with other elected officials to implement a system of internal controls to ensure compliance with federal grant requirements. District 3 County Commissioner: The County will work to design and implement a system of internal controls to ensure compliance with all applicable grant requirements 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.
The County will work to design and implement a system of internal controls to ensure compliance with all applicable grant requirements.
During the process of documenting the County?s internal controls regarding federal disbursements, we noted that Ottawa County has not established procedures to ensure compliance with the following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/Costs Principles; Period of Performance; Procurement and Suspension and Debarment; 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 with grant requirements and could lead to the 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 all requirements. Management Response: District 1 County Commissioner: I will work with other elected officials to gain an understanding of grant program requirements and to implement control procedures to ensure compliance with all requirements. District 2 County Commissioner: I was not in office during this fiscal year; however, I will work with other elected officials to implement a system of internal controls to ensure compliance with federal grant requirements. District 3 County Commissioner: The County will work to design and implement a system of internal controls to ensure compliance with all applicable grant requirements Criteria: 2 CFR ? 200.303(a) Internal Controls 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). 2 CFR ? 213 states, ?Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.? Additionally, 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.
Show full finding ▾Hide full finding ▴Finding 2019-021 ? Lack of Internal Controls Over Major Federal Program ? Highway Planning and Construction (Repeat Finding ? 2017-024) FEDERAL AGENCY: U.S. Department of Transportation ASSISTANCE LISTING: 20.205 FEDERAL PROGRAM NAME: Highway Planning and Construction FEDERAL AWARD NUMBER: BIA ? A13AC00042 and A16AC00032 FEDERAL AWARD YEAR: 2017 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Costs Principles; Period of Performance; Procurement and Suspension and Debarment; Special Tests and Provisions. QUESTIONED COSTS: $-0- Condition: During the process of documenting the County?s internal controls regarding federal disbursements, we noted that Ottawa County has not established procedures to ensure compliance with the following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/Costs Principles; Period of Performance; Procurement and Suspension and Debarment; 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 with grant requirements and could lead to the 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 all requirements. Management Response: District 1 County Commissioner: I will work with other elected officials to gain an understanding of grant program requirements and to implement control procedures to ensure compliance with all requirements. District 2 County Commissioner: I was not in office during this fiscal year; however, I will work with other elected officials to implement a system of internal controls to ensure compliance with federal grant requirements. District 3 County Commissioner: The County will work to design and implement a system of internal controls to ensure compliance with all applicable grant requirements Criteria: 2 CFR ? 200.303(a) Internal Controls 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). 2 CFR ? 213 states, ?Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.? Additionally, 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.
The County will work to design and implement a system of internal controls to ensure compliance with all applicable grant requirements.
Upon inquiry, review, and testwork of thirty-eight (38) or 100% of major program expenditures, the following weaknesses were noted: ? One (1) invoice totaling $150,910 could not be located. ? Five (5) right-of-way acquisitions totaling $11,588 were not supported by adequate documentation. 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 resulted in noncompliance with federal grant requirements and could lead to the 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 all requirements. Management Response: District 1 County Commissioner: I will work with other elected officials to gain an understanding of grant program requirements and to implement internal control procedures to ensure compliance with all requirements. District 2 County Commissioner: I was not in office at this time; however, I will work with the other elected officials to gain an understanding of requirements for this federal program and to implement internal control procedures to ensure the county is in compliance with all requirements. District 3 County Commissioner: The County will work to design and implement a system to establish and maintain effective internal control over federal awarded funds. This includes compliance with federal statutes, regulations and terms and conditions of the feral award to meet requirements for this program. Criteria: 2 CFR ? 200.303(a) Internal Controls 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). 2 CFR ? 200.84 Questioned Cost reads as follows: Questioned cost means a cost that is questioned by the auditor because of an audit finding: (a) Which resulted from a violation or possible violation of a statute, regulation, or the terms and conditions of a Federal award, including for fund used to match Federal funds: (b) Where the cost, at the time of the audit, are not supported by adequate documentation: or (c) Where the costs incurred appear unreasonable and do not reflect the actions a prudent person would take in the circumstances. 2 CFR ? 200.318 (a), General procurement standards, reads as follows: The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part. Additionally, 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.
Show full finding ▾Hide full finding ▴Finding 2019-022 ? Noncompliance with Compliance Requirements: A ? Activities Allowed or Unallowed and B ? Allowable Costs/Costs Principles ? Highway Planning and Construction FEDERAL AGENCY: U.S. Department of Transportation ASSISTANCE LISTING: 20.205 FEDERAL PROGRAM NAME: Highway Planning and Construction FEDERAL AWARD NUMBER: BIA ? A13AC00042 and A16AC00032 FEDERAL AWARD YEAR: 2017 CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Costs Principles QUESTIONED COSTS: $162,498 Condition: Upon inquiry, review, and testwork of thirty-eight (38) or 100% of major program expenditures, the following weaknesses were noted: ? One (1) invoice totaling $150,910 could not be located. ? Five (5) right-of-way acquisitions totaling $11,588 were not supported by adequate documentation. 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 resulted in noncompliance with federal grant requirements and could lead to the 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 all requirements. Management Response: District 1 County Commissioner: I will work with other elected officials to gain an understanding of grant program requirements and to implement internal control procedures to ensure compliance with all requirements. District 2 County Commissioner: I was not in office at this time; however, I will work with the other elected officials to gain an understanding of requirements for this federal program and to implement internal control procedures to ensure the county is in compliance with all requirements. District 3 County Commissioner: The County will work to design and implement a system to establish and maintain effective internal control over federal awarded funds. This includes compliance with federal statutes, regulations and terms and conditions of the feral award to meet requirements for this program. Criteria: 2 CFR ? 200.303(a) Internal Controls 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). 2 CFR ? 200.84 Questioned Cost reads as follows: Questioned cost means a cost that is questioned by the auditor because of an audit finding: (a) Which resulted from a violation or possible violation of a statute, regulation, or the terms and conditions of a Federal award, including for fund used to match Federal funds: (b) Where the cost, at the time of the audit, are not supported by adequate documentation: or (c) Where the costs incurred appear unreasonable and do not reflect the actions a prudent person would take in the circumstances. 2 CFR ? 200.318 (a), General procurement standards, reads as follows: The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part. Additionally, 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.
The County will work to design and implement a system to establish and maintain effective internal control over federal awarded funds. This includes compliance with federal statues, regulations, and terms and conditions of the federal award to meet requirements for this program.
FAC accepted this audit on April 4, 2022 — management decision was due October 4, 2022.
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