ROOSEVELT COUNTY

NONCOMPLIANCE WITH PROCUREMENT, SUSPENSION & DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027, YEAR ENDED JUNE 30, 2024 Criteria: Per section 13 of Treasury’s Final Rule FAQs and 2 CFR 200.214, counties must comply with the procurement standards set forth in 2 CFR 200.318, through 2 CFR 200.327, when using their SLFRF award funds to procure goods and services to carry out the objectives of their SLFRF award. In addition, 2 CFR 200.214, prohibits recipients from using SLFRF funds to enter into subawards and contracts with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs. Condition 1: The county did not verify that program recipients/participants were not suspended, debarred, or otherwise excluded from participation in the program. Condition 2: The county did not formally bid a communications upgrade pre-install project as required by federal procurement standards established in 2 CFR 300.19. Cause: The county does not have procurement policies and procedures in place that allows it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions. Questioned Costs: None Recommendation: Management should develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.

CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, PROCUREMENT AND SUSPENSION AND DEBARMENT Criteria: Per section 13 of Treasury’s Final Rule FAQs and 2 CFR 200.214, recipients are prohibited from using SLFRF funds to enter into subawards and contracts with parties at a lower tier, (a contractor, subcontractor, individual or supplier) that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs. Condition: The county did not verify eligibility for participation in the federal program for its third-party suppliers and contractors. Questioned Costs: None Cause: The county does not have procurement policies and procedures in place that allow it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions Recommendation: The county should develop a process to verify that all required parties are not suspended or debarred or otherwise excluded from participation in the federal program. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM, (2) collecting a certification from the entity, or (3) adding a clause or condition to the transaction with that entity (2 CFR section 180.300). Views of responsible officials and planned corrective actions: The government agrees with this finding and will adhere to the attached corrective action plan.

SEGREGATION OF DUTIES Criteria: Duties should be segregated to provide reasonable assurance that transactions are handled appropriately. Condition: There is a lack of segregation of duties among personnel. Effect: Transactions could be mishandled. Cause: There are a limited number of personnel for certain functions. Recommendation: The duties should be separated as much as possible, and alternative controls should be used to compensate for lack of separation. The governing board should provide some of these controls. Views of responsible officials and planned corrective actions: The government agrees with this finding and will adhere to the attached correction action plan.

AUDITOR PREPARED FINANCIAL STATEMENTS Criteria: As part of its internal control structure, it is the government?s responsibility to prepare its financial statements in accordance with generally accepted accounting principles (GAAP). Condition: The government does not have the expertise to prepare or evaluate the selection and application of accounting principles and resulting disclosures and presentations within the auditor prepared financial statements. Cause: The government is a small organization with limited resources. Effect: It is common for a small organization to rely on the audit firm to prepare the financial statements; however, an audit firm cannot be considered part of the government?s internal control by professional standards currently in effect. Since some presentations and disclosures may be material to the financial statements, this weakness in internal control would be classified as material. Recommendation: While it may not be cost effective to do so, we recommend the government consider hiring a qualified person to evaluate the auditor prepared financial statements. Views of responsible officials and planned corrective actions: The government agrees with this finding and will adhere to the attached correction action plan.