EIN: 910947136
UEI: GSA_MIGRATION
Data as of August 27, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 28, 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 March 28, 2022 (1613 days ago).
What is a management decision? →SCHEDULE OF FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Port of Ridgefield January 1, 2020 through December 31, 2020 2020-001 The Port lacked adequate internal controls for ensuring compliance with federal procurement and suspension and debarment requirements. CFDA Number and Title: 20.205 Highway Planning and Construction Federal Grantor Name: Department of Federal Highway Administration, Transportation Federal Award/Contract Number: N/A Pass-through Entity Name: Washington Department of Transportation Pass-through Award/Contract Number: HSR-STPR-STPD-HLP-1085(004) Questioned Cost Amount: $0 Description of Condition During fiscal year 2020, the Port spent $6,553,286 in Highway Planning and Construction grant funding. The Port used this grant funding for its Railroad Overpass project. Federal regulations require recipients to establish and follow internal controls for ensuring compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Procurement Federal regulations require grant recipients to follow their own written procurement procedures, which must reflect the most restrictive of applicable federal, state or local laws. Established procedures must conform to federal procurement standards (2 CFR 200.318-.327) to ensure recipients follow the most restrictive thresholds and methods when using federal funds. The Port had a written procurement policy, however, it did not include federal requirement thresholds, and it was less restrictive than federal thresholds for the procurement of public works. Suspension and debarment Federal requirements prohibit grant recipients from contracting with parties that have been suspended or debarred from doing business with the federal government. Whenever a government contracts for goods or services that it expects to equal or exceed $25,000, paid all or in part with federal funds, it must verify that the contractor is not suspended or debarred. Governments can verify a contractor?s status by obtaining written certification from the contractor, or it can insert a clause into the contract stating the contractor is not suspended or debarred. Alternatively, the government can check the U.S. General Services Administration?s Excluded Parties List System (EPLS). The government must perform this verification before entering into the contract, and it must keep documentation demonstrating compliance with this federal requirement. The Port?s controls were ineffective for ensuring that all contracted parties that were paid more than $25,000, all or in part with program funds, were not suspended or debarred. The Port did not obtain written certification, include a clause in the contract, or check the EPLS to verify that one of its three contractors was not suspended or debarred. We consider these deficiencies in internal controls to be material weaknesses that led to material noncompliance. These issues were not reported as findings in the prior audit. Cause of Condition Procurement Since the Port does not receive federal funds every year, staff did not know that the Port?s policies and procedures must include Uniform Guidance procurement standards. Suspension and debarment Port staff was aware of suspension and debarment verification requirements for applicable transactions. However, Port staff did not know that these requirements applied to a specific contractor the Port was required to use for work related to the Railroad Overpass project. Effect of Condition Procurement Without updated written policies and procedures, the Port is at greater risk of noncompliance with the most restrictive of federal, state or local procurement methods and requirements when using federal funds to procure contractors. While the Port did not have federal thresholds listed in its policies, we did verify that the Port properly procured the public works contractor for the Railroad Overpass project. Suspension and debarment Without adequate internal controls, the Port cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any program funds the Port used to pay contractors that have been suspended or debarred would be unallowable, and the federal grantor could potentially recover them. During fiscal year 2020, the Port used $424,881 of program funds to pay a contractor. We did verify the contractor was not suspended or debarred, so we are not questioning these costs. Recommendation Procurement We recommend the Port continue updating its written procurement policy to ensure it conforms to all federal regulations for procurement transactions. Suspension and debarment We recommend the Port strengthen its internal controls for ensuring that all contractors it expects to pay $25,000 or more, all or in part with federal funds, are not suspended or debarred. Port?s Response 1. Auditor?s Recommendations The Port concurs with the Auditor?s recommendations to update the Port?s written procurement policy. The purpose of the update is to ensure that the policy conforms with Federal regulations. Federal regulations are similar to Washington State procurement and public works laws but differ in some instances. A corrective action plan has been proposed. The Port also concurs with the Auditor?s recommendations to strengthen internal controls regarding verification of contractor eligibility to do business with the federal government or is excluded from federal projects. The purpose is to ensure that no Port contractor paid with federal grants funds is suspended or debarred from working on federal projects. A corrective action plan has been proposed. 2. Cause of Condition a. Procurement ? The Auditor?s description of the condition is accurate. The Port does not receive federal funds on an annual basis. b. Suspension and Debarment ? The Auditor?s description of the condition is accurate. The Port did not understand that under federal law the BNSF Railway would be considered a contractor. The Port believed that based on BNSF status as the holder of the right-of-way it was not a contractor under federal law. The Port appreciates that the Auditor included in the report that the specific contractor was not suspended or debarred. Auditor?s Remarks We appreciate the steps the Port is taking to resolve the issues noted, and will follow up during the next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, section 318, General procurement standards, establishes requirements for documented procurement procedures, which reflect applicable state, local, and federal laws and regulations. Title 2 CFR Part 180, OMB Guidelines to Agencies on Governmentwide Debarment and Suspension, establishes non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689.
Show full finding ▾Hide full finding ▴SCHEDULE OF FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Port of Ridgefield January 1, 2020 through December 31, 2020 2020-001 The Port lacked adequate internal controls for ensuring compliance with federal procurement and suspension and debarment requirements. CFDA Number and Title: 20.205 Highway Planning and Construction Federal Grantor Name: Department of Federal Highway Administration, Transportation Federal Award/Contract Number: N/A Pass-through Entity Name: Washington Department of Transportation Pass-through Award/Contract Number: HSR-STPR-STPD-HLP-1085(004) Questioned Cost Amount: $0 Description of Condition During fiscal year 2020, the Port spent $6,553,286 in Highway Planning and Construction grant funding. The Port used this grant funding for its Railroad Overpass project. Federal regulations require recipients to establish and follow internal controls for ensuring compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Procurement Federal regulations require grant recipients to follow their own written procurement procedures, which must reflect the most restrictive of applicable federal, state or local laws. Established procedures must conform to federal procurement standards (2 CFR 200.318-.327) to ensure recipients follow the most restrictive thresholds and methods when using federal funds. The Port had a written procurement policy, however, it did not include federal requirement thresholds, and it was less restrictive than federal thresholds for the procurement of public works. Suspension and debarment Federal requirements prohibit grant recipients from contracting with parties that have been suspended or debarred from doing business with the federal government. Whenever a government contracts for goods or services that it expects to equal or exceed $25,000, paid all or in part with federal funds, it must verify that the contractor is not suspended or debarred. Governments can verify a contractor?s status by obtaining written certification from the contractor, or it can insert a clause into the contract stating the contractor is not suspended or debarred. Alternatively, the government can check the U.S. General Services Administration?s Excluded Parties List System (EPLS). The government must perform this verification before entering into the contract, and it must keep documentation demonstrating compliance with this federal requirement. The Port?s controls were ineffective for ensuring that all contracted parties that were paid more than $25,000, all or in part with program funds, were not suspended or debarred. The Port did not obtain written certification, include a clause in the contract, or check the EPLS to verify that one of its three contractors was not suspended or debarred. We consider these deficiencies in internal controls to be material weaknesses that led to material noncompliance. These issues were not reported as findings in the prior audit. Cause of Condition Procurement Since the Port does not receive federal funds every year, staff did not know that the Port?s policies and procedures must include Uniform Guidance procurement standards. Suspension and debarment Port staff was aware of suspension and debarment verification requirements for applicable transactions. However, Port staff did not know that these requirements applied to a specific contractor the Port was required to use for work related to the Railroad Overpass project. Effect of Condition Procurement Without updated written policies and procedures, the Port is at greater risk of noncompliance with the most restrictive of federal, state or local procurement methods and requirements when using federal funds to procure contractors. While the Port did not have federal thresholds listed in its policies, we did verify that the Port properly procured the public works contractor for the Railroad Overpass project. Suspension and debarment Without adequate internal controls, the Port cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any program funds the Port used to pay contractors that have been suspended or debarred would be unallowable, and the federal grantor could potentially recover them. During fiscal year 2020, the Port used $424,881 of program funds to pay a contractor. We did verify the contractor was not suspended or debarred, so we are not questioning these costs. Recommendation Procurement We recommend the Port continue updating its written procurement policy to ensure it conforms to all federal regulations for procurement transactions. Suspension and debarment We recommend the Port strengthen its internal controls for ensuring that all contractors it expects to pay $25,000 or more, all or in part with federal funds, are not suspended or debarred. Port?s Response 1. Auditor?s Recommendations The Port concurs with the Auditor?s recommendations to update the Port?s written procurement policy. The purpose of the update is to ensure that the policy conforms with Federal regulations. Federal regulations are similar to Washington State procurement and public works laws but differ in some instances. A corrective action plan has been proposed. The Port also concurs with the Auditor?s recommendations to strengthen internal controls regarding verification of contractor eligibility to do business with the federal government or is excluded from federal projects. The purpose is to ensure that no Port contractor paid with federal grants funds is suspended or debarred from working on federal projects. A corrective action plan has been proposed. 2. Cause of Condition a. Procurement ? The Auditor?s description of the condition is accurate. The Port does not receive federal funds on an annual basis. b. Suspension and Debarment ? The Auditor?s description of the condition is accurate. The Port did not understand that under federal law the BNSF Railway would be considered a contractor. The Port believed that based on BNSF status as the holder of the right-of-way it was not a contractor under federal law. The Port appreciates that the Auditor included in the report that the specific contractor was not suspended or debarred. Auditor?s Remarks We appreciate the steps the Port is taking to resolve the issues noted, and will follow up during the next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, section 318, General procurement standards, establishes requirements for documented procurement procedures, which reflect applicable state, local, and federal laws and regulations. Title 2 CFR Part 180, OMB Guidelines to Agencies on Governmentwide Debarment and Suspension, establishes non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689.
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Port of Ridgefield January 1, 2020 through December 31, 2020 This schedule presents the corrective action planned by the Port for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2020-001 Finding caption: The Port lacked adequate internal controls for ensuring compliance with federal procurement and suspension and debarment requirements. Name, address, and telephone of Port?s contact person: Matthew Rosenberger, Accounting Manager 111 W Division St #1 Ridgefield WA, 98642 360-887-3873 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for non-concurrence). With respect to the procurement recommendation, the Port will be performing a review of Port procurement policies in the Q1 2022. As part of that review the Port will include the federal threshold for projects receiving federal funds. That policy will be in addition to and distinct from applicable state thresholds. For example, the current federal threshold for debarment verification is $25,000. The policy will include that threshold. With respect to the suspension and debarment recommendation and as part of the review described above, the Port will adopt a policy that the Port either 1) receive written certification from the contractor that it is not suspended or debarred, 2) include in its contracts a clause certifying that the contractor is not suspended or debarred, or 3) check the U.S. General Services Administration?s Excluded Parties List System (EPLS) prior to entering into any such contract and retain documentation demonstrating compliance for those projects funded fully or partially by federal grant dollars. Because the Port is an infrequent recipient of federal grant dollars and because federal rules are subject to change or modification, the policy will include guidance that Port staff review at the time of grant application the rules then in effect and confirm prior to entering into a contract for a project receiving federal grant funds. Anticipated date to complete the corrective action: 3/31/22
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