UTAH COUNTY GOVERNMENTLocal Government

US Department of Agriculture Program Name: Emergency Watershed Protection Program (EWP) CFDA #10.923 Grant Number: NR198D43xxxxC018 US Department of Housing and Urban Development Program Name: Covid-19 Community Development and Block Grants (Covid--CDBG) CFDA #14.218 Finding 2020 ? 001 Significant Deficiency/Compliance Reporting Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) (Transparency Act) that are codified in 2 CFR Part 170, direct recipients of grants who make first tier subawards of $25,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and report subaward data through FSRS. Condition: (1) EWP --The County did not report the subaward information for 2 subrecipients. The total of the subawards was $582,734. These subrecipients were the only ones receiving subawards exceeding $25,000 during the year. (2) Covid--CDBG?The County did not report subawards required to be reported under the Transparency Act. Effect: Two subawards were omitted from the required Transparency Act reporting. Cause: The County does not have policies and procedures in place to determine and track which subawards are subject to the Transparency Act. Recommendation: Policies and procedures should be implemented, and training should be conducted to ensure applicable employees are familiar with the Transparency Act requirements to ensure all applicable subawards are accounted for in the FSRS. Views of responsible officials and planned corrective actions: Finding: 2020-001 Agency: Utah County Government Name of Contact Person and Title: Jeremy Walker, Director of Financial Services Anticipated Completion Date: 12/31/2021 Agency?s Response: Concur Explanation: The County agrees with this finding and will implement the following: ? Develop policies and procedures that require confirmation that eligible subawards were reported in Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). ? Distribute policies and procedures. ? Train staff on new policies and procedures.

US Department of Agriculture, US Department of the Treasury, US Department of Health and Human Services, and US Department of Housing and Urban Development Passed through Utah Department of Health, Utah Department of Human Services, and Direct Programs Program Names: Emergency Watershed Protection Program, Coronavirus Relief Fund, Block Grants for Prevention and Treatment of Substance Abuse, and Community Development and Block Grants CFDA #?s: 10.923, 21.019, 93.959, and 14.218 Finding 2020?002 Significant Deficiency/ Compliance Subrecipient Monitoring Criteria: A pass-through entity (PTE) must: (1)Identify the award and applicable requirements by clearly identifying to the subrecipient that the award is a subaward, and by providing all information described in 2 CFR section200.331 (a)(1), and by providing all requirements imposed by the PTE on the subrecipient so that the federal award used in accordance with federal statutes and regulations, and by providing any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award; (2) Evaluate each subrecipient?s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring (auditing) related to the subaward. This evaluation of risk may include consideration of such factors as: (a) The subrecipient?s prior experience with the award, (b) The results of previous audits of the subrecipient, (c) Whether the subrecipient has new personnel or systems, and (d) the extent and results of Federal awarding agency monitoring (auditing) of the subrecipient; (3) Monitor (Audit) the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, does not violate the suspension and debarment compliance requirements, and achieves performance goals. In addition to procedures identified as necessary based upon the evaluation of subrecipient risk, or specifically required by the terms and conditions of the award, subaward monitoring must include: (a) Reviewing financial and special reports required by the PTE; (b) Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. and (c) Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section e200.521; (4) Ensure Accountability of For-Profit Subrecipient ? some federal awards may be passed through to for-profit entities. For-profit subrecipients are accountable to the PTE for the use of the federal funds provided. The PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward. The agreement with the for-profit subrecipient must describe applicable compliance requirements and the for-profit subrecipient?s compliance responsibility. Methods to ensure compliance for federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits (2 CFR section 200.501(h)). Condition: The County does not have adequate policies and procedures in place to monitor (audit) a subrecipient?s compliance with all applicable federal requirements. Effect: Without adequate monitoring (auditing) procedures, the County might not detect unallowed expenditures, improper payments to suspended or debarred entities, or receive incorrect or incomplete information from subrecipients. Cause: County employees were unaware of all the compliance requirements applicable to subrecipients. Recommendation: We recommend the County implement policies and procedures to ensure subrecipients comply with applicable rules and regulations. Views of responsible officials and planned corrective actions: Finding: 2020-002 Agency: Utah County Government Name of Contact Person and Title: Jeremy Walker, Director of Financial Services Anticipated Completion Date: 12/31/2021 Agency?s Response: Concur Explanation: The County agrees with this finding and will implement the following: ? Develop policies and procedures that require confirmation that subrecipients complied with requirements of federal awards. ? Distribute policies and procedures. ? Train staff on new policies and procedures.