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City of Brenham, TexasLocal Government

EIN: 746000404

UEI: LF2UCH3R6SW3

Audited by: Seidel Schroeder

Oversight agency: 14 [Department of Housing and Urban Development]

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Data as of August 28, 2026

City of Brenham, Texas7 audit years3 findings1 repeat
7
Audit Years
3
Total Findings
1
Repeat Findings
$5.8M
Federal Awards Expended (FY 2025)

FY 2025-09-30

LOW-RISK AUDITEE$5,835,056 federal awards expendedNo findings recorded this year

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 27, 2026. 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 September 27, 2026 (27 days from today).

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FY 2024-09-30

LOW-RISK AUDITEE$1,660,111 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 28, 2025 — management decision was due September 28, 2025.

FY 2023-09-30

$1,367,974 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.

FY 2022-09-30

$881,018 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 22, 2023 — management decision was due September 22, 2023.

FY 2021-09-30

$1,328,489 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 15, 2022 — management decision was due September 15, 2022.

FY 2020-09-30

$3,622,648 federal awards expended

FAC accepted this audit on March 30, 2021 — management decision was due September 30, 2021.

2020-001
Cost Allowability
REPEAT OF 2019-001OTHER MATTERS

The City contracted with professional engineers for projects funded by federal awards without following competitive proposal procedures. Criteria: Grant agreements require the City to follow local, state and/or federal procurement laws, regulation, and procedures. Cause: Following Texas state law regarding procurement of professional services, the City contracted with professional engineers with which it had prior experience to perform initial design surveys and continued to utilize their services once projects were approved for funding by federal awards. Effect: Professional engineering services related to grant number NR197442XXXXC037 totaling $12,310 and grant number NR197442XXXXC039 totaling $25,603 could have been disallowed. However, the expenditures have been approved and reimbursed by the granting agency. Questioned Costs: None Recommendation: The City should follow procurement policies and procedures included in federal contract provisions. Views of Responsible Officials and Planned Corrective Actions: During the year ended September 30, 2020, the City established procurement policies and procedures to include federal contract provisions and will follow those policies for future projects.

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Full finding narrative

Noncompliance DEPARTMENT OF AGRICULTURE EMERGENCY WATERSHED PROGRAM CFDA NO. 10.923 2020-001 Allowable Costs/Cost Principles Condition: The City contracted with professional engineers for projects funded by federal awards without following competitive proposal procedures. Criteria: Grant agreements require the City to follow local, state and/or federal procurement laws, regulation, and procedures. Cause: Following Texas state law regarding procurement of professional services, the City contracted with professional engineers with which it had prior experience to perform initial design surveys and continued to utilize their services once projects were approved for funding by federal awards. Effect: Professional engineering services related to grant number NR197442XXXXC037 totaling $12,310 and grant number NR197442XXXXC039 totaling $25,603 could have been disallowed. However, the expenditures have been approved and reimbursed by the granting agency. Questioned Costs: None Recommendation: The City should follow procurement policies and procedures included in federal contract provisions. Views of Responsible Officials and Planned Corrective Actions: During the year ended September 30, 2020, the City established procurement policies and procedures to include federal contract provisions and will follow those policies for future projects.

Corrective Action Plan

FINDINGS-FEDERAL AWARD PROGRAM AUDITS NONCOMPLIANCE DEPARTMENT OF AGRICULTURE 2020-001 Allowable Costs/Cost Principles ? Emergency Watershed Program CFDA No. 10.923 Recommendation: The City should follow procurement policies and procedures included in federal contract provisions. Action Taken: During the fiscal year 2020, the City completed a Grant Policies and Procedures Manual which was adopted by City Council on September 3, 2020. Among other items, this manual established procurement policies and procedures to include federal contract provisions. The City will follow these policies and procedures for future projects.

Prior Finding References

2019-001

About Allowable Costs / Cost Principles →

FY 2019-09-30

$1,329,473 federal awards expended

FAC accepted this audit on May 20, 2020 — management decision was due November 20, 2020.

2019-001
Cost Allowability
MODIFIED OPINIONQUESTIONED COSTS

The City contracted with professional engineers for projects funded by federal awards without following competitive proposal procedures. In addition, a contract with one engineering firm included a cost-plus fee structure. Criteria: Grant agreements require the City to follow local, state and/or federal procurement laws, regulations and procedures. Cause: Following Texas state law regarding procurement of professional services, the City contracted with professional engineers with which it had prior experience to perform initial storm damage assessments and continued to utilize their services once projects were approved for funding by federal awards. Effect: The cost of professional engineering services may be disallowed. Questioned Costs: See Schedule of Findings and Questioned Costs for chart/table. Recommendation: The City should establish procurement policies and procedures to include federal contract provisions. The City should also amend its engineering contracts to remove the cost-plus structure.

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Noncompliance DEPARTMENT OF HOMELAND SECURITY DISASTER GRANTS-PUBLIC ASSISTANCE CFDA 97.036 2019-001 Allowable Costs/Cost Principles Condition: The City contracted with professional engineers for projects funded by federal awards without following competitive proposal procedures. In addition, a contract with one engineering firm included a cost-plus fee structure. Criteria: Grant agreements require the City to follow local, state and/or federal procurement laws, regulations and procedures. Cause: Following Texas state law regarding procurement of professional services, the City contracted with professional engineers with which it had prior experience to perform initial storm damage assessments and continued to utilize their services once projects were approved for funding by federal awards. Effect: The cost of professional engineering services may be disallowed. Questioned Costs: See Schedule of Findings and Questioned Costs for chart/table. Recommendation: The City should establish procurement policies and procedures to include federal contract provisions. The City should also amend its engineering contracts to remove the cost-plus structure.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Actions: The City has established procurement policies and procedures to include federal contract provisions and has amended its engineering contracts to remove the cost-plus fee structure. It is the intent of the City, as advised by FEMA representatives, to submit these expenditures for reimbursement at project closeout noting an allowable exception based on Texas state law.

About Allowable Costs / Cost Principles →
2019-002
Other
MATERIAL WEAKNESS

The City does not have written policies, procedures, and standards of conduct for federal awards as required by Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Subparts D-Post Federal Award Requirements and E-Cost Principles. Criteria: The Uniform Guidance requires the City to have written policies, procedures and standards of conduct for federal awards. Cause: The City was unaware of a requirement to have written policies and procedures with respect to federal awards. Effect: The requirements of Subparts D-Post Federal Award Requirements and E-Cost Principles may not be followed. Recommendation: The City should establish written policies, procedures, and standards of conduct for federal awards in accordance with the Uniform Guidance.

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Full finding narrative

Material Weaknesses DEPARTMENT OF HOMELAND SECURITY DISASTER GRANTS-PUBLIC ASSISTANCE CFDA 97.036 2019-002 Federal Award Policies and Procedures Condition: The City does not have written policies, procedures, and standards of conduct for federal awards as required by Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Subparts D-Post Federal Award Requirements and E-Cost Principles. Criteria: The Uniform Guidance requires the City to have written policies, procedures and standards of conduct for federal awards. Cause: The City was unaware of a requirement to have written policies and procedures with respect to federal awards. Effect: The requirements of Subparts D-Post Federal Award Requirements and E-Cost Principles may not be followed. Recommendation: The City should establish written policies, procedures, and standards of conduct for federal awards in accordance with the Uniform Guidance.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Actions: The City has established procurement policies and procedures to include federal contract provisions and will establish and adopt written policies for federal awards.

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