HomeMy WebLinkAbout20191866.tiffCOLORADO
Division of Homeland Security
& Emergency Management
Department of Public Safety
9195 E. Mineral Avenue, Suite 200
Centennial, CO 80112
December 2, 2O19
Don Warden, Director of Finance & Administration
Weld County
P.O. Box 758
Greeley, CO 8O632
RECEIVED
JAN 16 2020
WELD COUNTY
^YMMI SON S
Re: Title 2 of the Code of Federal Regulations (2 CFR) Single Audit Review - Final Decision Letter — NO ACTION
REQUIRED
Dear Mr. Warden:
Your organization has received grants from the Colorado Division of Homeland Security and Emergency Management
(DHSEM). In accordance with 2 CFR, DHSEM is responsible for collecting and reviewing Single Audit reports from its
Subrecipients who have expended Federal funds of $750,000 or more within FY 2O18. During this review DHSEM
performs a review of audit findings related to Federal Awards passed through by DHSEM to Weld County. Per the
requirements of 2 CFR, the pass through entity (DHSEM) is responsible for issuance of a management decision
related to the Federal awards and the appropriateness of the Subrecipient's action plan.
DHSEM completed the review of the Single Audit package for Weld County for the period ending December 31, 2O18.
During our review of your organization's FY 2O18 Single Audit report, we noted no findings relating to your grant
programs passed -through by DHSEM that require corrective action by your organization or further follow up by
DHSEM.
This letter serves as final communication in reference to the review of your organization's Single Audit report for the
period ending December 31, 2O18. If you should have any concerns regarding this letter, please contact Justine
Willman at iustine.willman®state.co.us or 720.852.6712. We look forward to continuing to work together and hope
to provide assistance in ensuring that your entity and the State achieve compliance with all Federal requirements.
Sincerely,
M. Justine Willman
Grant Compliance Manager
justine.willmanPstate.co.us
720.595.6119 Mobile 1720.852.6712 Desk 1720.852.6750 Fax
9195 E Mineral Avenue, Suite 200, Centennial, CO 80112 P 720.852.6600 F 720.852.6768 dhsem.state.co.us
Jared Polls, Governor I Stan Hilkey, Executive Director
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COLORADO
Division of Homeland Security
& Emergency Management
Department of Public Safety
May 3, 2019
Barbara Connolly, Controller
Roy Rudisill, OEM Director
Weld County
1150 O Street
Greeley, CO 80631
Re: DHSEM Monitoring Site Visit Find Results — NO FOLLOW UP ACTION REQUIRED
Dear Ms. Connolly and Mr. Rudisill:
On behalf of the Colorado Department of Public Safety, Division of Homeland Security & Emergency Management
(DHSEM), we would like to thank you for your cooperation with the monitoring visit on March 12, 2019. The reason
for the site visit was not to perform an audit, but rather to conduct a monitoring review of your federally funded
grant programs (administered by DHSEM), the related processes/procedures, and the quality of documentation
being maintained to support program activities. Our goal of this review was to help you prepare for and respond to
future audits and/or reviews.
Our monitoring visit was required by the Federal Office of Management and Budget (OMB) Title 2 of the Code of
Federal Regulations § 200.331(e), as applicable, which states that DHSEM, as a pass -through entity of federal funds,
is responsible for performing on -site reviews of your program operations to ensure proper accountability and
compliance with program requirements and achievement of performance goals.
During our visit, we examined certain functions of your organization related to the administration of funds under
the: FEMA Public Assistance (PA) CFDA 97.036; FEMA Emergency Management Performance Grant (EMPG) CFDA
97.042; FEMA Hazard Mitigation Grant Program (HMGP) CFDA 97.039; HUD Community Development Block Grant —
Disaster Recovery (CDBG-DR) CFDA 14.269; PHMSA Hazardous Materials Emergency Preparedness (HMEP) CFDA
20.703; and State Disaster Emergency Fund (DEF) and the compliance requirements applicable to your grant(s) and
associated project(s). The objective of these monitoring activities was to make an assessment of performance
towards project objectives and an evaluation of compliance towards program requirements.
The results of these monitoring activities indicate that your organization is in compliance with the applicable federal
requirements, and no further action is required. Attachment 2 states that no issues required a Guidance Observation.
It is recommended that the County review and update its policies and procedures in areas listed in Attachment 3
attached hereto.
If you should have any questions regarding this letter, please contact the Subrecipient Monitoring Team at
CDPS_SRM@state.co.us or contact Justine Willman at 720.852.6712.
We thank you again for your cooperation and will continue to provide assistance to ensure that your entity and the
State continue to comply with all federal grant requirements.
Sincerely,
1_mtiva��. wiu.rutu..
M. Justine Willman
Grant Compliance Manager
9195 E Mineral Avenue, Suite 200, Centennial, CO 80112 P 720.852.6600 F 720.852.6768 dhsem.state.co.us
Jared Polis, Governor I Stan Hilkey, Executive Director
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2019-1866
Weld County
May 3, 2019
Page 2
Attachment 1: Scope Activities Performed
The objective of the Subrecipient Monitoring visit was to assess your organization's ability to maintain compliance
with the regulations governing the federal grants you have received through DHSEM. The following categories and
general scope were reviewed during our on -site monitoring visit as applicable:
Category
Control
Environment
Scope
Our assessment of your organization's control environment included a review of the following:
✓ Overall internal control structure (e.g. policies and procedures, reporting lines, etc.)
V Code of ethics, Conflict of interest certifications
V Prior experience with management of grant programs and Federal funding
VFamiliarity with DHSEM points of contact
✓ Implementation of corrective action resulting from audits and other monitoring activities
V Segregation ofduties for grant management functions
Allowable
Activities / Costs /
Expenditures
Our assessment of your organization's expenditures included a review of the following:
✓ Procedures for ensuring expenditures comply with cost principles
✓ Process for vaiding in -kind contributions and donated resources
✓ Allowability and review of travel and per -diem expenses
V Proper controls in the expenditure cycle (e.g. approval processes for expenditures)
Accounting
Our assessment of your organization's grant accounting included a review of the following:
✓ Validating use of cost centers for grant projects
V Maintenance of a chart of accounts for federal, state, and insurance funding
✓ Review of reconciliation practices and procedures
V Process for reconciling budget overruns and variances
Reporting
Our assessment of your organization's reporting practices included a review of the following:
✓ Policies and procedures governing reporting practices
✓ Supporting documentation for reported milestones and expenditures
✓ Communication of passed through funding to DHSEM and Federal agencies
Cash
Management And
Advances
Our assessment of your organization's cash management practices included a review of the
following:
V Processes established to manage cash advances in accordance with regulations
V Policies or procedures for timely payment of vendors
V Verifying that in -Bind contributions are used only for local match amounts
Equipment &
Inventory
Our assessment of your organization's equipment management practices included a review of
the following:
V Policies and procedures in place to manage equipment purchased with grant funding
V Maintenance of property records that reflect required data points
V Controls to protect equipment from theft, loss, or damage
✓ Tagging of assets
V Validation of proper disposition practices and policies
✓ Inventory practices
V Depreciation of assets in line with organizational depreciation schedules
V Documentation of maintenance procedures
9195 E Mineral Avenue, Suite 200, Centennial, CO 80112 P 720.852.6600 F 720.852.6768 dhsem.state.co.us
Jared Polls, Governor I Stan Hilkey, Executive Director
Weld County
May 3, 2019
Page 3
Labor & Time
Accounting
Our assessment of your organization's labor and time accounting practices included a review
of the following:
V Documentation of Job descriptions for employees splitting time between grant and non -
grant activities
V Review of salary and fringe benefit allocations to grant projects
V Support for administrative time and force account labor (timesheets)
V Compliance with Davis Bacon (as applicable)
Procurement &
Contracts
Our assessment of your organization's procurement practices included a review of the
following:
V Documentation of policies and procedures for procurement
V Review of contract types used under Federal grants
✓ Review of supporting procurement documentation and bid tabulations
V Review of contracts with vendors for proper flow down provisions
V Verification of use of debarment and suspension lists
✓ Utilization of minority and women owned businesses
V Use of geographical preference in bid criteria
V Use of contract management systems for managing vendors
Subrecipient
Monitoring
(Subaward)
Our assessment of your organization's subrecipient monitoring included a review of the
following:
✓ Determination of contract vs. subaward
V Proper documentation of pass through funding
V Compliance with FFATA, Single audit reporting
V Review of single audit results
✓ Follow up on subrecipient's corrective action plans
V Verification of subrecipient's use of grant flow down provisions
Project Progress
Our assessment of your organization's project progress monitoring included a review of the
following:
✓ Processes for accurately reporting project progress
V Documentation of why established goals were not met
V Comparison of actual project progress vs. reported progress
Record Retention
Our assessment of your organization's record retention practices included a review of the
following:
✓ Documented record retention policies and procedures
✓ Backup and secure storage of documentation
V Organization of supporting files
Other
In addition to the reviews listed, the following may have been reviewed or discussed:
V Follow up on variances from quarterly reports
✓ Feedback for DHSEM related to program administration
V Technical training on EMGrants Pro platform
V Need for in person training or guidance for grant programs
✓ Compliance with Title VI of the Civil Rights Act of 1964 and Title II of the American's with
Disabilities Act, 28 CFR 35.101 et seq., as applicable
9195 E Mineral Avenue, Suite 200, Centennial, CO 80112 P 720.852.6600 F 720.852.6768 dhsem.state.co.us
Jared Polis, Governor 1 Stan Hilkey, Executive Director
Weld County
May 3, 2019
Page 4
Attachment 2: Summary of Guidance Observations
Observations related to required guidance require your organization's response. During our visit, there were no
findings related to guidance issues, so no follow-up is needed.
Note: During our on -site monitoring visit, we provided initial results during our exit meeting based on the
documentation reviewed and interviews conducted. Since that time, it is possible that observations below were made
during the final review of documentation that were not discussed during the exit meeting.
9195 E Mineral Avenue, Suite 200, Centennial, CO 80112 P 720.852.6600 F 720.852.6768 dhsem.state.co.us
Jared Polis, Governor I Stan Hilkey, Executive Director
Weld County
May 3, 2019
Page 5
Attachment 3: Summary of Leading Practice Observations
Responses to observations related to Leading Practices are optional. These recommendations are derived from
leading practices and interpretations of federal guidance and are provided for Weld County's consideration.
ding Observation d.
Area of Review:
General / Entity -Level Standards
Applicable
Programs:
All Programs Reviewed
Observations
During our review and discussion with Weld County (County), it was noted that the County has
a travel policy, a code of conduct, a compensation policy, and a record retention policy.
However, no consolidated written grant management policy is in place, as was recommended
from the January, 2017 letter.
Guidance
Grants Awards after December 26, 2014
2 CFR Subpart D (200,303)(a) The non -Federal entity must establish and maintain effective
internal control over the Federal award that provides reasonable assurance that the non -
Federal entity is managing the Federal award in compliance with Federal statutes, regulations,
and the terms and conditions of the Federal award. These internal controls should be in
compliance with guidance in "Standards for Internal Control in the Federal Government" issued
by the Comptroller General of the United States or the "Internal Control Integrated
Framework", issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
Risks:
Failure to maintain a uniform policy on grant management activities and requirements exposes
the County to potential inconsistencies in the administration of grants.
Recommendations:
The County has established policies and procedures to govern the administration of the grants
received from DHSEM. However, we continue to recommend that the County establish a
consolidated Grants Management Policy as an easily accessible reference in the event of future
disasters.
Subrecipient's
Response &
Corrective Action
Plan (Optional):
NOTE: RESPONSES TO LEADING PRACTICE OBSERVATIONS ARE OPTIONAL
9195 E Mineral Avenue, Suite 200, Centennial, CO 80112 P 720.852.6600 F 720.852.6768 dhsem.state.co.us
Jared Polls, Governor I Stan Hilkey, Executive Director
Weld County
May 3, 2019
Page 6
ftng.Practice Observation #2
Area of Review:
General / Entity Lewl Standards
Applicable
Programs:
All Programs Reviewed
Observations:
During our preparation for the site visit with the County, we discovered that the County website
main page has a drop down list entitled "How Do I" with tab for contacting the County via email,
mail, and phone regrading concerns and/or comments. The County Human Resources
Department also provides assistance with complaints. However, during our site visit, the
County stated that no official whistleblower policy is in place.
Guidance:
Grant Awards after December 26, 2014
2 CFR 200.113 Mandatory Disclosures. The non -Federal entity or applicant for a Federal award
must disclose, in a timely manner, in writing to the Federal awarding agency or pass -through
entity all violations of Federal criminal law involving fraud, bribery, or gratuity violations
potentially affecting the federal award.
2 CFR 200.331 (61 (b) All pass -through entities must evaluate each subrecipient's risk of
noncompliance with Federal statutes, regulations, and the terms and conditions of the
subaward for purposes of determining the appropriate subrecipient monitoring.
Grants Prior to December 26, 2014
44 CFR 13.12(a) A grantee or subgrantee may be considered "high risk" if an awarding agency
determines that a grantee or subgrantee: (1) Has a history of unsatisfactory performance, or
(2) Is not financially stable, or (3) Has a management system which does not meet the
management standards set forth in this part, or (4) Has not conformed to terms and conditions
of previous awards, or (5) Is otherwise not responsible; and if the awarding agency determines
that an award will be made, special conditions and/or restrictions shall correspond to the high
risk condition and shall be included in the award.
Risks:
Failure to develop mechanisms for reporting fraud increases the risk of fraud going unreported,
generating additional financial and legal risk for the subrecipient. Failure to make the required
disclosures can result in any of the remedies described in 2 CFR 200.338 Remedies for
noncompliance, including suspension or debarment.
Recommendations:
Develop mechanisms for reporting fraud and other misdeeds, and communicate these
mechanisms to all employees.
See Attachment 4 for a sample Whistleblower Mechanism policy.
Sub recipient's
Response &
Corrective Action
Plan (Optional):
NOTE: RESPONSES TO LEADING PRACTICE OBSERVATIONS ARE OPTIONAL
9195 E Mineral Avenue, Suite 200, Centennial, CO 80112 P 720.852.6600 F 720.852.6768 dhsem.state.co.us
Jared Polls, Governor I Stan Hilkey, Executive Director
Weld County
May 3, 2019
Page 7
' . serration #3
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Area of Review:
Equipment and Property Management
Applicable
Programs:
All Programs Reviewed
Observations
During our discussion with Weld County, it was noted that equipment was purchased with
FEMA PW 860 grant funds from DHSEM. However, we noted during our site visit that Article
VI of the County Code addresses fixed assets and that the County's inventory of fixed assets is
updated annually. The County's inventory contains all property with a useful life of at least 3
years and a minimum value of $5,000 which in turn is inventoried on an annual basis. We
advised that the inventory is required for items with a useful life of at least one (1) year, rather
than 3 years, and a minimum value of $5,000.
Guidance
Grant Awards after December 26, 2014
2 CFR 200.313
(d) Management requirements. Procedures for managing equipment (including
replacement equipment), whether acquired in whole or in part under a Federal award, until
disposition takes place will, as a minimum, meet the following requirements:
(1) Property records must be maintained that include a description of the property, a
serial number or other identification number, the source of funding for the property (including
the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal
participation in the project costs for the Federal award under which the property was acquired,
the location, use and condition of the property, and any ultimate disposition data including the
date of disposal and sale price of the property.
(2) A physical inventory of the property must be taken and the results reconciled with the
property records at least once every two years.
(3) A control system must be developed to ensure adequate safeguards to prevent loss,
damage, or theft of the property. Any loss, damage, or theft must be investigated.
(4) Adequate maintenance procedures must be developed to keep the property in good
condition.
(5) If the non -Federal entity is authorized or required to sell the property, proper sales
procedures must be established to ensure the highest possible return.
Grants Prior to December 26, 2014
44 CFR 13.32 (d) (3) A control system must be developed to ensure adequate safeguards to
prevent loss, damage, or theft of the property. Any loss, damage, or theft shall be investigated.
Risks:
Failure to maintain a policy for property records or inventory requirements may lead to
mismanaged federal assets which could ultimately lead to improper disposition of a federally -
participated -in asset.
Recommendations:
Update the physical inventory requirements to replace the 3 year useful life with a 1 year useful
life for inclusion of an item purchased with Federal grant funds on the inventory, which is in
addition to the minimum value of $5,000.
9195 E Mineral Avenue, Suite 200, Centennial, CO 80112 P 720.852.6600 F 720.852.6768 dhsem.state.co.us
Jared Polls, Governor I Stan Hickey, Executive Director
Weld County
May 3, 2019
Page 8
Sub red pie nt's
Response &
Corrective Action
Plan (Optional):
NOTE: RESPONSES TO LEADING PRACTICE OBSERVATIONS ARE OPTIONAL
- —
Leadirtg Practice ®bser
Area of Review:
Procurement
Applicable
Programs:
All Programs Reviewed.
Observations:
While procurement was a primary issue for non -exigent contract work performed as a result of
the floods in September 2013, the vast majority of the underlying policies and procedures have
been corrected. We noted during our interview that Article IV of the County Code, Section 5-4-
130 requires compliance with grant requirements. However, the County should also include
that the most stringent policy applies to procurement to ensure the correct policy is followed
for future purchases using Federal grant funds.
Guidance:
Grant Awards after December 26, 2014
2 CFR Subpart (200.319)(b) The non -Federal entity must conduct procurements in a manner
that prohibits the use of statutorily or administratively imposed state, local, or tribal
geographical preferences in the evaluation of bids or proposals, except in those cases where
applicable Federal statutes expressly mandate or encourage geographic preference. Nothing in
this section preempts state licensing laws. When contracting for architectural and engineering
[ALE) services, geographic location may be a selection criterion provided its application leaves
an appropriate number of qualified firms, given the nature and size of the project, to compete
for the contract. 2 CFR Subpart D (200.319)(c) The non -Federal entity must have written
procedures for procurement transactions. These procedures must ensure that all solicitations:
(1) Incorporate a clear and accurate description of the technical requirements for the material,
product, or service to be procured. Such description must not, in competitive procurements,
contain features which unduly restrict competition. The description may include a statement
of the qualitative nature of the material, product or service to be procured and, when
necessary, must set forth those minimum essential characteristics and standards to which it
must conform if it is to satisfy its intended use. Detailed product specifications should be
avoided if at all possible. When it is impractical or uneconomical to make a clear and accurate
description of the technical requirements, a "brand name or equivalent" description may be
used as a means to define the performance or other salient requirements of procurement. The
specific features of the named brand which must be met by offers must be clearly stated; and
(2) Identify all requirements which the offerors must fulfill and all other factors to be used in
evaluating bids or proposals.
2 CFR 200.3241. This step should provide proper diligence in testing the procurement policies.
2. Procurement documentation must be provided to the pass through entity upon request.
Grants Prior to December 26, 2014
44 CFR 13.36(b)(3) Grantees and subgrantees will maintain a written code of standards of
conduct governing the performance of their employees engaged in the award and
9195 E Mineral Avenue, Suite 200, Centennial, CO 80112 P 720.852.6600 F 720.852.6768 dhsem.state.co.us
Jared Polls, Governor I Stan Hilkey, Executive Director
Weld County
May 3, 2019
Page 9
administration of contracts. No employee, officer or agent of the grantee or subgrantee shall
participate in selection, or in the award or administration of a contract supported by Federal
funds if a conflict of interest, real or apparent, would be involved. Such a conflict would arise
when: (i) The employee, officer or agent, (ii) Any member of his immediate family, (iii) His or
her partner, or (iv) An organization which employs, or is about to employ, any of the above, has
a financial or other interest in the firm selected for award. The grantee's or subgrantee's
officers, employees or agents will neither solicit nor accept gratuities, favors or anything of
monetary value from contractors, potential contractors, or parties to subagreements. Grantee
and subgrantees may set minimum rules where the financial interest is not substantial or the
gift is an unsolicited item of nominal intrinsic value. To the extent permitted by State or local
law or regulations, such standards or conduct will provide for penalties, sanctions, or other
disciplinary actions for violations of such standards by the grantee's and subgrantee's officers,
employees, or agents, or by contractors or their agents. The awarding agency may in regulation
provide additional prohibitions relative to real, apparent, or potential conflicts of interest.
Risks:
Failure to comply with Federal procurement regulations can lead to deobligation of funding.
Recommendations:
Update written policies and procedures to include the provision that the most stringent of
procurement requirements will be followed.
Subrecipient's
Response &
Corrective Action
Plan (Optional):
NOTE: RESPONSES TO LEADING PRACTICE OBSERVATIONS ARE OPTIONAL
9195 E Mineral Avenue, Suite 200, Centennial, CO 80112 P 720.852.6600 F 720.852.6768 dhsem.state.co.us
Jared Polls, Governor I Stan Hilkey, Executive Director
Weld County
May 3, 2019
Page 10
Attachment 4: Guidance for Leading Practices
Whistleblower Mechanism — Sample Policy
City of Colorado Springs, Office of the City Auditor, Fraud Prevention and Detection Policy
1. Background
The City of Colorado Springs Fraud Prevention and Detection Policy (Policy) is established to facilitate the
development of controls which will aid in the prevention and detection of fraud against the City of Colorado
Springs (City). It is the intent of the City Auditor to promote consistent organizational behavior by providing
guidelines and assigning responsibility for the development of controls and conduct of investigations. The
City Auditor website contains a Fraud and Abuse Reporting page. This page contains information for the
reader on how to report a potential fraud and how the report will be handled. Fraud awareness and reporting
posters have been distributed by the City Auditor to all City and enterprise bulletin boards. It is also to be
displayed in all remote construction locations and distributed to new contractors by the CSU procurement
office.
2. Authority
This Policy derives its authority from City Code § 1.2.703, which states:
ENSURE PUBLIC ACCOUNTABILITY:
The City Auditor shall ensure that administrative officials are held publicly accountable for their use
of public funds and the other resources at their disposal. The City Auditor shall investigate whether
or not laws are being administered in the public interest, determine if there have been abuses of
discretion, arbitrary actions or errors of judgment, and shall encourage diligence on the part of
administrative officials. (Ord. 11-18)
3. Applicability
This Policy applies to City Council, the Mayor, all employees of the City of Colorado Springs, including all
its enterprise operations, and members of its Boards, Committees, or Commissions.
4. Scope
This Policy applies to any suspected fraud, abuse, or similar irregularity against the City.
5. Objective
This Policy is set forth to communicate the City Auditor's Policy regarding prevention, reporting and
investigating suspected fraud, abuse, and similar irregularities. The City Auditor desires to create an
9195 E Mineral Avenue, Suite 200, Centennial, CO 80112 P 720.852.6600 F 720.852.6768 dhsem.state.co.us
Jared Polls, Governor 1 Stan Hilkey, Executive Director
Weld County
May 3, 2019
Page 11
environment in which employees and/or citizens can report any suspicions of fraud. This Policy provides
management with specific guidelines and
responsibilities regarding appropriate actions in conducting investigations of alleged fraud and similar
improprieties.
6. Definitions
Abuse refers to, but is not limited to:
• Improper or misuse of authority,
• Improper or misuse of City property, equipment, materials, records, or other resources,
• Waste of public funds, or
• Any similar or related irregularity.
Abuse can occur in financial or non -financial settings. When considering if an event or action might be
construed as being abusive, one should consider if it would pass public scrutiny.
Chief Executive Officer, or CEO, shall mean highest-ranking person responsible for the municipal
government and the City's enterprises, including Colorado Springs Utilities.
. City of Colorado Springs is a home rule city and Colorado municipal corporation, to include all its
enterprises, specifically Colorado Springs Utilities, as well as all Boards, Committees, and Commissions
appointed by City Council.
City Employee shall mean all employees of the municipal government and all the enterprises of
the City.
Fraud or other irregularity refers to, but is not limited to:
• Any dishonest or fraudulent act,
• Forgery or alteration of any document or account,
• Forgery or alteration of a check, bank draft, or any other financial document,
• Misappropriation of funds, securities, supplies, or other assets,
• Impropriety in the handling or reporting of money or financial transactions,
• Profiteering as a result of insider knowledge of City activities,
• Disclosing confidential and/or proprietary information to outside parties,
• Accepting or seeking anything of material value from consultants, contractors, vendors, or
persons providing services or materials to the City,
• Destruction, removal, or inappropriate use of records, furniture, fixtures, and equipment,
• Any claim for reimbursement of expenses that are not made for the exclusive benefit of the City,
• Any computer related activity involving the alteration, destruction, forgery or manipulation of
data for fraudulent purposes, or
• Any similar or related irregularity.
9195 E Mineral Avenue, Suite 200, Centennial, CO 80112 P 720.852.6600 F 720.852.6768 dhsem.state.co.us
Jared Polis, Governor I Stan Hilkey, Executive Director
Weld County
May 3, 2019
Page 12
Management shall mean those individuals who have been placed in a position of trust by the CEO to assist
in carrying out the objectives of that part of the City for which they are employed.
7. General Policy and Responsibilities
Preventive Controls
Each CEO is responsible for instituting and maintaining a system of internal control to provide reasonable
assurance for the prevention and detection of fraud, abuse, or other irregularity. Management should be
familiar with the types of improprieties that might occur within their area of responsibility and be alert
for any indications of such conduct. The City Auditor shall conduct periodic reviews, report on deficiencies,
and make recommendations to management and the CEO regarding internal controls.
Upon completion of any investigation where weaknesses in internal control have been identified, the City
Auditor will work with the entity staff to strengthen controls to lower the risk of future or repeated
occurrence.
9195 E Mineral Avenue, Suite 200, Centennial, CO 80112 P 720.852.6600 F 720.852.6768 dhsem.state.co.us
Jared Polis, Governor I Stan Hilkey, Executive Director
Hello