TOWN OF WHEATLAND, WYOMING

Finding 2025-002 – Cash Management (Reimbursement Request Error) Federal Program: Coronavirus State and Local Fiscal Recovery Funds ALN: 21.027 Compliance Requirement: Cash Management Type of Finding: Significant Deficiency in Internal Control Over Compliance and Noncompliance Criteria Per 2 CFR §200.305(b)(1) and the terms of the subaward, the pass-through entity required the non-Federal entity to use the reimbursement method. Under this method, payment may be requested only for actual, allowable, and properly supported expenditures. Additionally, per 2 CFR §§200.302 and 200.303, the non-Federal entity must maintain financial management systems and internal controls sufficient to ensure reimbursement requests are accurate and supported by appropriate documentation. Condition The Town of Wheatland requested reimbursement totaling $74,113.15 in excess of actual, allowable, and supported expenditures due to an error in compiling reimbursement request amounts. As a result, the request was not fully supported by underlying documentation at the time of submission. The error was later identified by the Town and corrected through a subsequent reimbursement adjustment. Cause The condition resulted from insufficient review procedures over reimbursement requests, including a lack of detailed reconciliation between requested amounts and supporting expense documentation prior to submission. Effect The Town temporarily requested federal funds in excess of allowable and supported expenditures, resulting in noncompliance with cash management requirements. Questioned Costs None. Repeat Finding No. Recommendation We recommend the Town strengthen internal controls over reimbursement requests by implementing a secondary review of reimbursement calculations prior to submission, establishing a formal reconciliation process between requested amounts and supporting documentation, and using a standardized checklist to verify the completeness and accuracy of reimbursement requests. Views of Responsible Officials Management agrees with the finding and has corrected the identified error. Additional review procedures and reconciliations will be implemented to ensure reimbursement requests are accurate and fully supported prior to submission.

Finding 2025-003 – Suspension and Debarment Federal Program: Coronavirus State and Local Fiscal Recovery Funds ALN: 21.027 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria Per 2 CFR §180.300 and 2 CFR §200.214, non-Federal entities are prohibited from entering into covered transactions with parties that are suspended or debarred. Covered transactions are defined in 2 CFR Part 180, Subpart B. Non-Federal entities must verify the suspension and debarment status of participants through the System for Award Management (SAM.gov) or by obtaining certification from the contractor or subrecipient. Condition During testing of procurement and contract files, the Town did not retain documentation demonstrating that contractors were verified against SAM.gov. Additionally, contracts reviewed did not include provisions requiring contractors to certify that they and their subcontractors were not suspended or debarred. Cause The Town does not have a formalized process to ensure verification of contractor eligibility through SAM.gov or inclusion of required suspension and debarment certification language in contracts. Effect Failure to verify contractor eligibility increases the risk that the Town could enter into agreements with suspended or debarred parties, resulting in noncompliance with federal requirements. Questioned Costs None. Repeat Finding No. Recommendation We recommend the Town implement procedures to verify and document contractor eligibility through SAM.gov for all applicable procurements and to include required suspension and debarment certification language in all contracts and subawards. Supporting documentation should be retained in the procurement file. Views of Responsible Officials Management agrees with the finding and will implement procedures to verify contractor eligibility through SAM.gov and retain appropriate documentation in procurement files.

Finding 2025-004 – Reporting Federal Program: Coronavirus State and Local Fiscal Recovery Funds ALN: 21.027 Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance and Noncompliance Criteria Per 2 CFR §200.328, non-Federal entities must submit financial and performance reports that are accurate, current, and complete. Additionally, per 2 CFR §200.303, entities must maintain effective internal control over Federal awards. Treasury SLFRF guidance requires Project and Expenditure (P&E) Reports to provide complete and accurate project information. Condition The Town’s March 2025 Project and Expenditure Report contained a project description that revenue replacement funds were used on payroll costs, when the costs were construction related. This error was not identified prior to submission. Cause The condition resulted from insufficient review of financial and narrative reporting elements. Effect The report submitted to Treasury was not accurate, resulting in noncompliance with federal reporting requirements. Questioned Costs None. Repeat Finding No. Recommendation We recommend the Town strengthen controls over SLFRF reporting by establishing documented review and approval controls, ensuring alignment between project descriptions and actual use of funds, and providing training on reporting requirements. Views of Responsible Officials Management agrees with the finding and will strengthen review procedures to ensure financial and narrative reports are accurate, complete, and consistent with underlying records.

2021-002 U.S. Department of Transportation Passed Through Wyoming Department of Aeronautics Division Assistance Listing # 20.106, Airport Improvement Program Pass-through Grant Identification # 3-56-0030-010-2018, 3-56-0030-011-2018 Procurement, Suspension, and Debarment Significant Deficiency in Internal Control over Compliance Prior Year Finding 2020-001 Criteria: Federal regulations 2 CFR 200.318 states that the Town must use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in 2 CFR 200.318 through 200.326. In addition, 2 C.F.R, 200.303 states, the Town, as a recipient of federal funds, must establish and maintain effective internal control over its federal awards that provides reasonable assurance that the Town is managing the federal awards in compliance with federal statutes, regulations, and the award terms and conditions. Condition: As noted in a prior year, the Town does not have a documented procurement policy. In addition, the procurement procedures followed by the Town did not include all of the requirements under the Uniform Guidance procurement standards. Our testing noted that the Town followed its procurement procedures that were developed using best practices. Cause: The Town has not documented a procurement policy that complies with the Code of Federal Regulations (CRF). Effect or Potential Effect: Lack of a formal, documented procurement policy may result in entering into a procurement that may not be in compliance with federal standards and is required by the CRF. Questioned Costs: None. Context: This is an unresolved prior year finding. Repeat Finding: Yes Recommendation: We recommend that the Town formally document and adopt a procurement policy that is in compliance with federal regulations. Views of Responsible Officials: We agree with the finding as presented above. We will adopt an official written procurement policy. The Town identified an employee on staff to oversee the procurement process. This individual ensures that Town employees are following the procurement process. The procurement manual will be reviewed annually for updates.

2020-001 U.S. Department of Transportation Passed Through Wyoming Aeronautics Division CFDA # 20.106, Airport Improvement Program Pass-through Grant Identification # 076441617 Procurement, Suspension, and Debarment Significant Deficiency in Internal Control over Compliance Criteria: Federal regulations 2 CFR 200.318 states that the Town must use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in 2 CFR 200.318 through 200.326. In addition, 2 C.F.R, 200.303 states, the Town, as a recipient of federal funds, must establish and maintain effective internal control over its federal awards that provides reasonable assurance that the Town is managing the federal awards in compliance with federal statutes, regulations, and the award terms and conditions. Condition: During our testing, we noted that the Town does not have a documented procurement policy. In addition, the procurement procedures followed by the Town did not include all of the requirements under the Uniform Guidance procurement standards. Our testing noted that the Town followed its procurement procedures that were developed using best practices. Cause: The Town has not documented a procurement policy that complies with federal regulations. Effect: Failure to have a documented procurement policy may result in entering into a procurement that may not be in compliance with federal standards. Questioned Costs: None reported. Context: We tested the contract that the Town entered into under the grant. We noted that the Town had gone out to bid for the contract and was awarded based on the Town?s procurement procedures. A statistical sample was not used in testing. Repeat Finding: No Recommendation: We recommend that the Town adopt and document a procurement policy that is in compliance with federal regulations. Views of Responsible Officials: We agree with the finding as presented and will adopt an official procurement policy. We will have our procurement policy in a written document. The Town identified an employee on staff to oversee the procurement process. This individual ensures that Town employees are following the procurement process. The Procurement manual will be reviewed annually for updates.