Sheridan CountyLocal Government

Significant Deficiencies in Internal Control over Compliance 2025-005 – Procurement, Suspension and Debarment Program: Partners for Fish and Wildlife Federal Assistance Listing No: 15.631 Federal Agency: U.S. Department of Interior Federal Award Identification Number: F22AC02789-00/F21AC02494-00 Year: 2024 Criteria or Specific Requirement Uniform Guidance requires non-federal entities to maintain written procurement procedures that provide for full and open competition and comply with applicable federal, state, and local laws and regulations. In addition, 2 CFR §180 and §200.213 require non-federal entities to ensure that vendors receiving federal funds are not suspended or debarred, and to have procedures in place to verify vendor eligibility prior to contract award. Condition The Weed & Pest District does not have formal, written policies or procedures governing procurement activities, including required procurement methods, documentation standards, and approval thresholds. Additionally, the Weed & Pest District lacks documented procedures to verify and confirm that vendors are not suspended or debarred prior to entering into contracts or making payments with federal funds. Independently, we verified that the contractor was not suspended or debarred. Independently, we verified that the contractor was not suspended or debarred. Cause Weed and Pest District has not established formal procurement and suspension and debarment policies due to limited administrative resources and a reliance on informal practices rather than documented policies. Effect or Potential Effect Without formal procurement and suspension and debarment policies, Weed & Pest District faces an increased risk of noncompliance with federal regulations. This raises the likelihood of unallowable activities or questioned costs, reduced competition, procurement inefficiencies, and potential contracts with ineligible vendors. Continued noncompliance could result in required repayment of federal funds, or other sanctions from grantor agencies. Questioned Costs None identified. Context The Weed & Pest District did not have formal policies for procurement, suspension and debarment. Identification of a Repeat Finding No Recommendation We recommend that Weed and Pest District develop, adopt, and implement written procurement and suspension and debarment policies and procedures in accordance with Uniform Guidance. Alternatively, Weed and Pest District could consider adopting the County’s procurement and suspension and debarment policies. In addition, Weed and Pest District should establish processes and controls to ensure compliance with these policies. Views of Responsible Officials Management agrees with the finding and plans to develop and formally adopt procurement and suspension and debarment policies. Implementation is expected to occur during the next fiscal year.

Significant Deficiencies in Internal Control over Compliance 2024-005 - Reporting Program: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing No: 21.027 Federal Agency: U.S. Department of Treasury Federal Award Identification Number: None Year: 2023 Direct Criteria or Specific Requirement Coronavirus State and Local Fiscal Recovery Funds require that grantees must submit an annual performance report with data on obligations and expenditures, and capital expenditures. Reporting compliance requirements state that required reports for federal awards should be supported by applicable accounting or performance records. Condition Internal controls for the retention of documentation supporting data on required report submitted to the U.S. Department of Treasury were not followed. Additionally, the reports were not submitted timely. Cause The County’s management and grant personnel prepared the report in collaboration with several individuals to assure understanding of the information required and accuracy of the information. After preparation of the report, supporting documentation was not retained and the report was submitted late. Effect or Potential Effect Without full compliance with the requirements for reporting, the County could be required to repay all amounts expended for these purchases. Questioned Costs None identified. Context The County did not file the report timely, nor was supporting documentation retained for the data included in the annual report submitted to the Department of Treasury. Identification of a Repeat Finding No Recommendation We recommend the County review its policies and procedures regarding submission of reports to granting agencies to assure the documentation supporting the reported data reported is retained and the reports are filed timely. Views of Responsible Officials • Grants Administrator will ensure that login access is maintained in the U.S. Department of Treasury portal. This includes signing up for email notification of pending due dates and communications released through the portal. • Grants Administrator will create a separate folder containing all projects and contracts that fall under ARPA funding. This folder will be updated monthly or as needed to ensure all documents are available for the annual audit. • Grants Administrator will coordinate with departments being awarded additional ARPA funding to ensure reporting requirements are met and completed within assigned timelines.

Significant Deficiencies in Internal Control over Compliance 2023-001 - Procurement, Suspension and Debarment Program: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing No: 21.027 Federal Agency: U.S. Department of Treasury Federal Award Identification Number: None Year: 2023 Direct Criteria or Specific Requirement Suspension and Debarment – Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services that are expected to equal or exceed $25,000. When a non-federal entity enters into a covered transaction, the non-federal entity must verify that the entity or person is not suspended or debarred. 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 SAM.gov, (2) collecting a certification from the entity or person, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). The non-federal entity must have internal controls designed and operating the ensure compliance with the suspension and debarment requirements. Condition Internal controls over entering into several transactions with a suspended or debarred party were not followed on an applicable purchase. Sheridan County’s (the “County) management indicated that a search on SAM was not performed and retained and suspension and debarment language was not appropriately included in contracts exceeding $25,000. Cause The County’s grant personnel advised that the absence of SAM search documentation was missed during their review of the grant documentation, as well as suspension and debarment language from the contracts for services. Effect or Potential Effect Without full compliance with the requirements for procurement, suspension and debarment, the County could be required to repay all amounts expended for these purchases. Questioned Costs None identified. Context The County had four contracts subject to the suspension and debarment compliance requirement. The District did not retain SAM search results to document compliance with verification that the contractor was not suspended or debarred prior to entering into the contract and suspension and debarment language did not exist in the contracts. Identification of a Repeat Finding No Recommendation We recommend the County review its policies and procedures to ensure compliance with suspension and debarment compliance requirement is documented. The County may consider collecting a certification from the entity or adding a clause or condition to the covered transaction with that entity. Additionally, the County may consider developing a checklist to make sure all required documentation is maintained in the grant file. Views of Responsible Officials Sheridan County will modify its template contract used for these types of transactions to include a certification of compliance related to suspension and debarment from the person or entity, so that each contract entered into in the future will be compliant. See Corrective Action Plan.