Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 24, 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 September 24, 2025, which was (329 days ago).
What is a management decision? →Condition: Hill County is responsible for complying with Uniform Guidance and the Suspension and Debarment compliance requirement as required by the contract and federal award documents for ARPA funds. Criteria: Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300. Context: In reviewing contract HC 22-120, the County was unable to provide proof that, prior to entering the contract, the County verified the contractor was not suspended, debarred, or otherwise excluded pursuant to 21 CFR section 19.300. Cause: The County’s Procurement Policy does not address Suspension and Debarment when performed internally rather than by a third party. Effect: Contractors may be suspended, debarred, or otherwise excluded pursuant to 21 CFR section 19.300, thus putting the County out of compliance with the federal award. Recommendation: Prior to entering into any subawards and contracts with award funds, the County should verify the contractor was not suspended, debarred, or otherwise excluded pursuant to 21 CFR section 19.300, and document accordingly. Planned Corrective Action: “The County spoke with all the grant coordinators communicating this requirement. The County is aware to check all new contractors. They have requested the information from contractors. The Procurement Policy is under review at this time. The County Attorney issued a statement about the process.”
The County and the grant writers are aware of this requirement to obtain this letter from SAMS. The County will update the Procurement Policy to address Suspension and Debarment when performed internally and will ensure that staff responsible for federal grant awards understand the requirement and will verify and document compliance. Finding will be resolved by June 30, 2025. We will be working with the County Attorney and the grant writers. We look to see a positive change in this deficiency over the next year. The County and grant coordinators are obtaining the documentation from SAMS. The Procurement Policy amendment was issued September 30, 2024. The amendment included the reasons for the requirement, instructions and examples of the requirement.
2022-003
Condition: Hill County is responsible for complying with Uniform Guidance and all compliance requirements as required by the contract and federal award documents for reimbursement grants, as it relates to recording of the related award expenditures. Criteria: Prior to payment of expenditures with award funds, recipients must verify proper account and fund recording, pursuant to 2 CFR section 200.500. Context: In reviewing and compiling the federal award expenditures for testing, we noted the County posted several journal voucher entries to change the original recording of numerous expenditures, either to record as ARPA expenditures or to remove as ARPA expenditures to another fund and/or award. In addition, several expenditures were only partially applied to ARPA with the rest applied to other funding sources, but were not segregated as such in the accounting system. Cause: There appears to be confusion between departments in which expenditures are to be coded as ARPA and which are not. County personnel should utilize approved project budgets in order to have the accounting and financial records properly recorded and reflected at the time of the transaction. County personnel should also clearly record any transactions that are covered by multiple funding sources as such. Effect: Expenditures may be submitted for reimbursement more than once, or to more than a single grant award, thus putting the County out of compliance with the federal award and potentially resulting in a duplication in funding. Recommendation: Prior to payment of expenditures with award funds, the County should closely monitor the expenditures as compared to each project budget and verify the expenditures are properly recorded to the appropriate award, pursuant to 2 CFR section 200.500, and document accordingly. Any subsequent change recorded via a journal voucher entry should also be properly documented and approved. Planned Corrective Action: “The coding of the invoices has improved. There is a detailed list of how each vendor should be coded. There are still times invoices need to transfer to a different fund in order to utilize the funding more efficiently. The grant coordinator has discussed everything. The transfers that are done have already been approved and paid. The expenditures are transferred to match the grant coordinator. Expenditure transfers can be done if the expenditure was incorrectly coded.”
Hill County is responsible for complying with Uniform Guidance and all compliance requirements as required by the contract and federal award documents for reimbursement grants, as it relates to recording of the related award expenditures. Prior to payment of expenditures with award funds, recipients must verify proper account and fund recording, pursuant to 2 CFR section 200.500. The coding of the invoices has improved. There is a detailed list of how each vendor should be coded. There are still times invoices need to transfer to a different fund in order to utilize the funding more efficiently. The grant coordinator has discussed everything. The tracking sheets are double checked with county accounting system. The transfers that are done have already been approved and paid. The expenditures are transferred to match the grant coordinator. Expenditure transfers can be done if the expenditure was incorrectly codes.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 20, 2023. 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 April 20, 2024, which was (851 days ago).
What is a management decision? →Condition: Hill County is responsible for complying with Uniform Guidance and the Suspension and Debarment compliance requirement as required by the contract and federal award documents for ARPA funds. Criteria: Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300. Context: In reviewing contract HC 22-120, the County was unable to provide proof that, prior to entering the contract, the County verified the contractor was not suspended, debarred, or otherwise excluded pursuant to 21 CFR section 19.300. Cause: The County’s Procurement Policy does not address Suspension and Debarment when performed internally rather than by a third party. Effect: Contractors may be suspended, debarred, or otherwise excluded pursuant to 21 CFR section 19.300, thus putting the County out of compliance with the federal award. Recommendation: Prior to entering into any subawards and contracts with award funds, the County should verify the contractor was not suspended, debarred, or otherwise excluded pursuant to 21 CFR section 19.300, and document accordingly. Planned Corrective Action: The County will update the Procurement Policy to address Suspension and Debarment when performed internally and will ensure that staff responsible for federal grant awards understands the requirement and will verify and document compliance.
The County will update the Procurement Policy to address Suspension and Debarment when performed internally and will ensure that staff responsible for federal grant awards understands the requirement and will verify and document compliance.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 22, 2021. 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 22, 2021, which was (1823 days ago).
What is a management decision? →Internal Control Over Federal Awards: Aging Cluster (93.044/93.045/93.053) #2020-002: Criteria: Hill County is responsible for implementing proper internal controls over sub-recipient monitoring as required by the contract and federal award. Condition: As part of our evaluation of the County?s internal control and compliance, we noted the County does not have a formal policy and internal controls for sub-recipient monitoring. Context: Annual contract for sub-recipient services for fiscal year 2020 with the Rocky Boy Tribal Council. Cause: The County does not have a formal policy regarding internal controls over sub-recipient monitoring in order to ensure all monitoring requirements are completed. Effect: The sub-recipient, and in turn, the County, may not be in compliance with the contract and meeting its match requirements, which could cause a loss of funding for the County. Recommendation: The County should establish formal internal controls over sub-recipient monitoring, including documenting site visits when they occur and developing a process for monitoring the sub-recipient meets the requirements of their contract. Planned Corrective Action: The County will perform visits to The Rocky Boy Senior Center three times per fiscal year. These visits will be documented and assessment of sub-recipient match requirements per contracts will be monitored to ensure compliance with the contracts. These match figures will be documented each site visit to ensure the match is being met by Rocky Boy Tribal Council Contract. In addition: ? Insurance coverage and written policies for service of Congregate and Home Delivered Meals will be kept on file at the County?s Council on Aging (HCCA). ? The HCCA will continue to document participant information and meal numbers in the State of Montana Aging Services Tracking System each month. ? Monthly menu's will be requested and kept on file at the HCCA to ensure each meal contains a minimum of 1/3 of the recommended Daily Allowance (RDA) of vitamins and minerals.
Planned Corrective Action: The County will perform visits to The Rocky Boy Senior Center three times per fiscal year. These visits will be documented and assessment of sub-recipient match requirements per contracts will be monitored to ensure compliance with the contracts. These match figures will be documented each site visit to ensure the match is being met by Rocky Boy Tribal Council Contract. In addition: ? Insurance coverage and written policies for service of Congregate and Home Delivered Meals will be kept on file at the County?s Council on Aging (HCCA). ? The HCCA will continue to document participant information and meal numbers in the State of Montana Aging Services Tracking System each month. ? Monthly menu's will be requested and kept on file at the HCCA to ensure each meal contains a minimum of 1/3 of the recommended Daily Allowance (RDA) of vitamins and minerals.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 12, 2021. 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 April 12, 2022, which was (1590 days ago).
What is a management decision? →Internal Control Over Federal Awards: Aging Cluster (93.044/93.045/93.053) #2019-002: Criteria: Hill County is responsible for implementing proper internal controls over sub-recipient monitoring as required by the contract and federal award. Condition: As part of our evaluation of the County?s internal control and compliance, we noted the County does not have a formal policy and internal controls for sub-recipient monitoring. Context: Annual contract for sub-recipient services for fiscal year 2020 with the Rocky Boy Tribal Council. Cause: The County does not have a formal policy regarding internal controls over sub-recipient monitoring in order to ensure all monitoring requirements are completed. Effect: The sub-recipient, and in turn, the County, may not be in compliance with the contract and meeting its match requirements, which could cause a loss of funding for the County. Recommendation: The County should establish formal internal controls over sub-recipient monitoring, including documenting site visits when they occur and developing a process for monitoring the sub-recipient meets the requirements of their contract. Planned Corrective Action: The County will perform visits to The Rocky Boy Senior Center three times per fiscal year. These visits will be documented and assessment of sub-recipient match requirements per contracts will be monitored to ensure compliance with the contracts. These match figures will be documented each site visit to ensure the match is being met by Rocky Boy Tribal Council Contract. In addition: ? Insurance coverage and written policies for service of Congregate and Home Delivered Meals will be kept on file at the County?s Council on Aging (HCCA). ? The HCCA will continue to document participant information and meal numbers in the State of Montana Aging Services Tracking System each month. ? Monthly menu's will be requested and kept on file at the HCCA to ensure each meal contains a minimum of 1/3 of the recommended Daily Allowance (RDA) of vitamins and minerals.
June 19, 2021 Anderson ZurMuehlen & Co. 330 4th Street Havre MT 59501 Dear Sir or Madam: Pursuant to the single audits completed by Anderson ZurMuehlen & Co., this letter serves as the County's response to their findings #2017-003, #2018-004 and #2019-003. Hill County has reviewed each finding and feel with the significant staff turnover in the Clerk & Recorder's and Commissioner's office there was lack of knowledge between Hill County and the Auditor's on the necessity of a single audit. We feel the Federal Programs were provided but were overlooked. We will be in contact with the Auditors for future audits and make sure they receive all the mandatory information.
2018-003
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 26, 2021. 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 April 26, 2022, which was (1576 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
2017-002
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 26, 2021. 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 April 26, 2022, which was (1576 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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