Audit 21083

FY End
2022-12-31
Total Expended
$1.47B
Findings
8
Programs
99
Organization: City of Chicago (IL)
Year: 2022 Accepted: 2023-08-07

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
25341 2022-002 Significant Deficiency - AE
25342 2022-002 Significant Deficiency - AE
25343 2022-003 Significant Deficiency - A
25344 2022-004 Significant Deficiency - M
601783 2022-002 Significant Deficiency - AE
601784 2022-002 Significant Deficiency - AE
601785 2022-003 Significant Deficiency - A
601786 2022-004 Significant Deficiency - M

Programs

ALN Program Spent Major Findings
21.027 Coronavirus State and Local Fiscal Recovery Funds $443.69M Yes 0
93.600 Head Start $67.10M Yes 0
20.106 Airport Improvement Program, Covid-19 Airports Programs, and Infrastructure Investment and Jobs Act Program $46.03M Yes 0
93.268 Immunization Cooperative Agreements $41.29M - 0
97.067 Homeland Security Grant Program $39.20M Yes 0
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $32.84M - 0
14.218 Community Development Block Grants/entitlement Grants $29.63M - 0
14.231 Emergency Solutions Grant Program $26.33M - 0
93.914 Hiv Emergency Relief Project Grants $25.51M - 0
14.239 Home Investment Partnerships Program $24.25M - 0
93.569 Community Services Block Grant $12.09M - 0
93.940 Hiv Prevention Activities_health Department Based $8.97M Yes 0
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $8.71M Yes 0
93.069 Public Health Emergency Preparedness $8.12M Yes 0
16.710 Public Safety Partnership and Community Policing Grants $8.06M Yes 0
20.205 Highway Planning and Construction $6.63M Yes 0
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $5.41M - 0
97.024 Emergency Food and Shelter National Board Program $4.79M Yes 2
93.994 Maternal and Child Health Services Block Grant to the States $4.55M Yes 0
66.468 Drinking Water State Revolving Fund $4.24M - 0
97.075 Rail and Transit Security Grant Program $4.14M - 0
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $4.02M - 0
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $3.94M Yes 0
66.458 Clean Water State Revolving Fund $3.91M - 0
20.507 Federal Transit_formula Grants $3.38M - 0
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $3.23M - 0
93.889 National Bioterrorism Hospital Preparedness Program $3.22M - 0
93.053 Nutrition Services Incentive Program $2.80M - 0
93.136 Injury Prevention and Control Research and State and Community Based Programs $2.51M - 0
93.686 Ending the Hiv Epidemic: A Plan for America Ryan White Hiv/aids Program Parts A and B (b) $2.27M - 0
16.922 Equitable Sharing Program $2.23M - 0
14.905 Lead Hazard Reduction Demonstration Grant Program $2.18M - 0
16.738 Edward Byrne Memorial Justice Assistance Grant Program $2.03M - 0
97.056 Port Security Grant Program $1.74M - 0
93.977 Sexually Transmitted Diseases (std) Prevention and Control Grants $1.66M - 0
93.667 Social Services Block Grant $1.62M - 0
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $1.55M - 0
93.052 National Family Caregiver Support, Title Iii, Part E $1.45M - 0
93.137 Community Programs to Improve Minority Health Grant Program $1.32M - 0
59.075 Shuttered Venue Operators Grant Program $1.26M - 0
14.881 Moving to Work Demonstration Program $1.17M - 0
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $913,351 - 0
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $912,747 - 0
93.944 Human Immunodeficiency Virus (hiv)/acquired Immunodeficiency Virus Syndrome (aids) Surveillance $878,013 - 0
16.575 Crime Victim Assistance $738,615 - 0
21.023 Emergency Rental Assistance Program $641,780 Yes 1
20.616 National Priority Safety Programs $573,786 - 0
20.500 Federal Transit_capital Investment Grants $541,453 - 0
93.575 Child Care and Development Block Grant $520,772 Yes 0
45.024 Promotion of the Arts_grants to Organizations and Individuals $500,000 - 0
97.133 Preparing for Emerging Threats and Hazards $428,856 - 0
94.011 Americorps Seniors Foster Grandparent Program (fgp) $415,780 - 0
93.470 Alzheimer's Disease Program Initiative (adpi) $409,534 - 0
66.039 Diesel Emissions Reduction Act (dera) National Grants $394,240 - 0
16.838 Comprehensive Opioid, Stimulant, and Other Substances Use Program $386,629 - 0
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $364,431 - 0
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $332,633 - 0
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $332,541 - 0
93.197 Childhood Lead Poisoning Prevention Projects_state and Local Childhood Lead Poisoning Prevention and Surveillance of Blood Lead Levels in Children $319,732 - 0
16.582 Crime Victim Assistance/discretionary Grants $291,357 - 0
20.600 State and Community Highway Safety $232,462 - 0
66.802 Superfund State, Political Subdivision, and Indian Tribe Site-Specific Cooperative Agreements $230,852 - 0
97.106 Securing the Cities Program $210,660 - 0
94.016 Americorps Seniors Senior Companion Program (scp) $200,375 - 0
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $189,969 - 0
45.025 Promotion of the Arts_partnership Agreements $140,200 - 0
93.071 Medicare Enrollment Assistance Program $115,517 - 0
16.827 Justice Reinvestment Initiative $110,599 - 0
16.320 Services for Trafficking Victims $110,183 - 0
93.959 Block Grants for Prevention and Treatment of Substance Abuse $98,207 - 0
93.042 Special Programs for the Aging_title Vii, Chapter 2_long Term Care Ombudsman Services for Older Individuals $95,418 - 0
20.703 Interagency Hazardous Materials Public Sector Training and Planning Grants $95,365 - 0
16.588 Violence Against Women Formula Grants $92,248 - 0
93.270 Viral Hepatitis Prevention and Control $78,630 - 0
97.044 Assistance to Firefighters Grant $74,880 - 0
20.314 Railroad Development $57,649 - 0
16.540 Juvenile Justice and Delinquency Prevention $50,254 - 0
10.675 Urban and Community Forestry Program $49,180 - 0
45.310 Grants to States $47,592 - 0
10.559 Summer Food Service Program for Children $43,266 - 0
93.350 National Center for Advancing Translational Sciences $39,505 - 0
14.256 Neighborhood Stabilization Program $19,533 - 0
10.025 Plant and Animal Disease, Pest Control, and Animal Care $12,869 - 0
16.609 Project Safe Neighborhoods $11,096 - 0
93.041 Special Programs for the Aging_title Vii, Chapter 3_programs for Prevention of Elder Abuse, Neglect, and Exploitation $10,640 - 0
66.818 Brownfields Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Cooperative Agreements $9,013 - 0
21.016 Equitable Sharing $6,502 - 0
97.039 Hazard Mitigation Grant $3,788 - 0
16.833 National Sexual Assault Kit Initiative $3,552 - 0
14.264 Neighborhood Stabilization Program $3,262 - 0
14.241 Housing Opportunities for Persons with Aids $2,000 - 0
10.558 Child and Adult Care Food Program $1,570 - 0
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $199 - 0
93.671 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $0 - 0
20.933 National Infrastructure Investments $-271 - 0
84.425 Education Stabilization Fund $-410 - 0
93.048 Special Programs for the Aging_title Iv_and Title Ii_discretionary Projects $-7,500 - 0
20.614 National Highway Traffic Safety Administration (nhtsa) Discretionary Safety Grants and Cooperative Agreements $-54,086 - 0
21.019 Coronavirus Relief Fund $-1.34M - 0

Contacts

Name Title Type
NDHBBJ4B1LN5 Chasse Rehwinkel Auditee
3127428178 Amanda Blomberg Auditor
No contacts on file

Notes to SEFA

Title: NOTE 2 BASIS OF PRESENTATION Accounting Policies: NOTE 1 REPORTING ENTITY - The City of Chicago (the City) is a governmental entity established by laws of the State of Illinois and has the powers of a body corporate, as defined in the statutes. All significant operations of the City are included in the scope of the Office of Management and Budget (OMB) requirements contained in 2 CFR Part 200, Subpart F (Single Audit). The U.S. Department of Health and Human Services (HHS) has been designated as the Citys cognizant agency for the Single Audit. The reporting entity for the City is based upon criteria established by the Governmental Accounting Standards Board.Programs Subject to Single Audit A Schedule of Expenditures of Federal Awards (SEFA) is presented for each federal program and a summary of expenditures by federal agency is as follows:U.S. Department of Agriculture$4,127,946U.S. Department of Housing and Urban Development 194,631,706U.S. Department of Justice 14,812,470 U.S. Department of Transportation 288,328,664U.S. Department of Treasury 513,160,736 U.S. National Endowment for the Arts 655,200U.S. Institute of Museum and Library Services 1,060,957U.S. Small Business Administration 1,264,933 U.S. Environmental Protection Agency8,789,362U.S. Department of Education-410U.S. Department of Health and Human Services 357,965,902 Research and Development Cluster79,593U.S. Corporation for National and Community Service 616,155U.S. Department of Homeland Security 83,426,893 Total Expenditures of Federal Awards $ 1,468,920,107 Passenger Facility Charges collected and expended, as prescribed by Sections 9110 and 9111 of the Aviation Safety and Capacity Expansion Act of 1990 issued by the Federal Aviation Administration of the United States Department of Transportation, are not included in this Single Audit report and are audited separately. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The accompanying schedule of expenditures of federal awards (the schedule) includes the federal award activity of the City of Chicago under programs of the federal government for the year ended December 31, 2022. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The schedule presents only a selected portion of the operations of the City of Chicago and accordingly, it is not intended to and does not present the financial position, changes in net position or cash flows of the City of Chicago.
Title: NOTE 3 SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Accounting Policies: NOTE 1 REPORTING ENTITY - The City of Chicago (the City) is a governmental entity established by laws of the State of Illinois and has the powers of a body corporate, as defined in the statutes. All significant operations of the City are included in the scope of the Office of Management and Budget (OMB) requirements contained in 2 CFR Part 200, Subpart F (Single Audit). The U.S. Department of Health and Human Services (HHS) has been designated as the Citys cognizant agency for the Single Audit. The reporting entity for the City is based upon criteria established by the Governmental Accounting Standards Board.Programs Subject to Single Audit A Schedule of Expenditures of Federal Awards (SEFA) is presented for each federal program and a summary of expenditures by federal agency is as follows:U.S. Department of Agriculture$4,127,946U.S. Department of Housing and Urban Development 194,631,706U.S. Department of Justice 14,812,470 U.S. Department of Transportation 288,328,664U.S. Department of Treasury 513,160,736 U.S. National Endowment for the Arts 655,200U.S. Institute of Museum and Library Services 1,060,957U.S. Small Business Administration 1,264,933 U.S. Environmental Protection Agency8,789,362U.S. Department of Education-410U.S. Department of Health and Human Services 357,965,902 Research and Development Cluster79,593U.S. Corporation for National and Community Service 616,155U.S. Department of Homeland Security 83,426,893 Total Expenditures of Federal Awards $ 1,468,920,107 Passenger Facility Charges collected and expended, as prescribed by Sections 9110 and 9111 of the Aviation Safety and Capacity Expansion Act of 1990 issued by the Federal Aviation Administration of the United States Department of Transportation, are not included in this Single Audit report and are audited separately. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Expenditures reported on the schedule are generally reported on the accrual or modified accrual basis of accounting depending on the type of fund. Some expenditures are reported when the reimbursement is received due to uncertainty of the source of funding at the time the expenditure is incurred. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, as applicable, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. Pass-through entity identifying numbers are presented where available.Certain financial awards were received by the City in the form of noncash direct assistance. These noncash awards are included on the schedule under ALN 93.268. The schedule of expenditures of federal awards includes a column titled Non-Federal Expenditures. Amounts reported in this column include the Citys required match for federal programs.The City has a cost allocation plan for allocation of common and indirect costs related to grant programs. The amounts allocated to 2022 grant programs are based primarily on 2021 budgeted amounts. Variances between actual costs and budgeted amounts are adjusted on a prospective basis. A copy of the cost allocation plan is kept on file at the City. The Citys cost allocation plan for 2022 has been prepared on a Direct Cost Base that does conform to the direct cost bases in the Uniform Guidance. The Citys 2022 Cost Allocation Plan (Local Organization Cost Allocation Plan LOCAP) was provided for review and negotiation to the Citys indirect cost cognizant agency. This LOCAP was subsequently negotiated and approved during 2022. The City has not elected to use the 10% de minimis indirect cost rate allowed by the Uniform Guidance. Individual City departments indirect cost rate proposals (ICRPs) for 2022 have been prepared on a Salaries and Wages plus all Fringe Benefits (S&W+FB) Direct Cost Base that does conform to the OMB Uniform Guidance. The 2022 Indirect Cost Rate Agreements related to the ICRPs for the Chicago Departments of Planning and Development, Housing, Public Health, and Family and Support Services were negotiated, approved, and signed by the Citys indirect cost cognizant agency and included provisional indirect cost rates for these departments extending from 1/1/2023 through 12/31/2025. Federal/State Commingled Funds The City of Chicago receives various federal awards that are passed through the State of Illinois. Many of these contracts contain a blend of state and federal awards. To the extent practical, the federal funding has been segregated from the state funding based on information provided by the state agencies. In some instances, individual state contracts contain multiple federal ALNs and the City has segregated the federal dollars associated with each contract award based on information received by the pass-through state agency. Due to the timing differences between the pass-through agency fiscal year end and the Citys reporting period, allocation differences may result. The state contract for the Child Care program (federal cluster 93.575/93.596), passed through the Illinois Department of Human Services (IDHS), has been considered a Type A cluster for audit testing purposes each year. The final allocation of federal expenditures varies depending on the most recent available information provided by IDHS and may be reported under both ALNs or one ALN. For FY2022 the Child Care program included federal funds confirmed by IDHS for 93.575 and 93.596.
Title: NOTE 3 SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (cont.) Accounting Policies: NOTE 1 REPORTING ENTITY - The City of Chicago (the City) is a governmental entity established by laws of the State of Illinois and has the powers of a body corporate, as defined in the statutes. All significant operations of the City are included in the scope of the Office of Management and Budget (OMB) requirements contained in 2 CFR Part 200, Subpart F (Single Audit). The U.S. Department of Health and Human Services (HHS) has been designated as the Citys cognizant agency for the Single Audit. The reporting entity for the City is based upon criteria established by the Governmental Accounting Standards Board.Programs Subject to Single Audit A Schedule of Expenditures of Federal Awards (SEFA) is presented for each federal program and a summary of expenditures by federal agency is as follows:U.S. Department of Agriculture$4,127,946U.S. Department of Housing and Urban Development 194,631,706U.S. Department of Justice 14,812,470 U.S. Department of Transportation 288,328,664U.S. Department of Treasury 513,160,736 U.S. National Endowment for the Arts 655,200U.S. Institute of Museum and Library Services 1,060,957U.S. Small Business Administration 1,264,933 U.S. Environmental Protection Agency8,789,362U.S. Department of Education-410U.S. Department of Health and Human Services 357,965,902 Research and Development Cluster79,593U.S. Corporation for National and Community Service 616,155U.S. Department of Homeland Security 83,426,893 Total Expenditures of Federal Awards $ 1,468,920,107 Passenger Facility Charges collected and expended, as prescribed by Sections 9110 and 9111 of the Aviation Safety and Capacity Expansion Act of 1990 issued by the Federal Aviation Administration of the United States Department of Transportation, are not included in this Single Audit report and are audited separately. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. COVID-19While continuing to recover from the impacts of the COVID-19 pandemic the City received revenues such as federal and state grants including $385.0 million of ARP Act funds applied to replace lost revenues due to the impacts of the COVID-19 pandemic totaling $1,855.0 million. These revenues were primarily applied to respond to the COVID-19 pandemic, such as housing and rental assistance, and public safety, as well as provide essential government services.In addition, the City is eligible for the Federal Emergency Management Agency (FEMA) Public Assistance Grant and in FY2022 received reimbursements for eligible costs incurred in FY2020 and FY2021 under this grant in the amount of $36,373 and $32,799,985 respectively, as reflected under ALN 97.036 in the Schedule of Expenditures for Federal Awards.Midway and OHare AirportsMidway was awarded a total of $172.4 million of COVID-19 Relief Funds. Excluding Concessionaire Relief Grants, Midway has applied $161.7 million of the COVID-19 Relief Funds through 2022 to airline rates and charges. Additionally, the City will apply $8.6 million of the Grants directly to Concessionaire Relief in 2023 and future years. O'Hare was awarded a total of $651.8 million of COVID-19 Relief Funds. Excluding Concessionaire Relief Grants, the City has applied $526.0 million of the COVID-19 Relief Funds through 2022 to airline rates and Passenger Facility and Customer Facility charges and has $43.1 million of funds remaining to be applied in 2023 and future years. Additionally, the City will apply $35.0 million of the Grants directly to Concessionaire Relief in 2023.

Finding Details

FINDING 2022-002 Assistance Listing Number 21.023 COVID-19 Emergency Rental Assistance Program Federal Agency U.S. Department of Treasury Pass-through Agency Not applicable Award Numbers / Years 2022 City Departments Department of Housing Criteria: According to Treasury guidance, recipients of the Emergency Rental Assistance Program (ERAP) are expected to develop guidelines for determining eligibility of beneficiaries. The City contracted with a local agency to make eligibility determinations and authorize the related payments to beneficiaries based on the guidelines established by the City. The City purchased a software program to assist in the record-keeping and documentation of the case management process from intake to eligibility determinations to payment authorization. Condition/Context: After conducting an extensive analysis of payments made under ERAP, the City has determined that there are potential unallowable payments that were made to ineligible beneficiaries. In addition, the City noted that some eligibility determinations were made and approved by the same person employed by the contractor, resulting in a lack of internal controls over the process. The City is in the process of investigating the validity and extent of potential unallowable payments made. In a sample of 60 benefit payments made, we noted 8 instances where the eligibility determination was approved by the same person who made the determination. Our sample was not statistically valid. Effect: It is possible that program payments were made to ineligible participants. Questioned Costs: Questioned costs cannot be determined at this time. Cause: Payments to potentially ineligible beneficiaries were likely due to the large volume of applications processed by the contractor required in a short amount of time. According to Treasury guidelines, the burden of proof of meeting eligibility guidelines is low; therefore, applicants may have provided inaccurate data in order to receive payments under the program. The software system used by the contractor appears to be lacking certain controls that would ensure proper segregation of duties between personnel determining eligibility and personnel reviewing eligibility determinations. Recommendation: We recommend the City continue to investigate questionable cases to determine the validity of the payments made and to quantify the amount of ineligible payments made. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2022-002 Assistance Listing Number 21.023 COVID-19 Emergency Rental Assistance Program Federal Agency U.S. Department of Treasury Pass-through Agency Not applicable Award Numbers / Years 2022 City Departments Department of Housing Criteria: According to Treasury guidance, recipients of the Emergency Rental Assistance Program (ERAP) are expected to develop guidelines for determining eligibility of beneficiaries. The City contracted with a local agency to make eligibility determinations and authorize the related payments to beneficiaries based on the guidelines established by the City. The City purchased a software program to assist in the record-keeping and documentation of the case management process from intake to eligibility determinations to payment authorization. Condition/Context: After conducting an extensive analysis of payments made under ERAP, the City has determined that there are potential unallowable payments that were made to ineligible beneficiaries. In addition, the City noted that some eligibility determinations were made and approved by the same person employed by the contractor, resulting in a lack of internal controls over the process. The City is in the process of investigating the validity and extent of potential unallowable payments made. In a sample of 60 benefit payments made, we noted 8 instances where the eligibility determination was approved by the same person who made the determination. Our sample was not statistically valid. Effect: It is possible that program payments were made to ineligible participants. Questioned Costs: Questioned costs cannot be determined at this time. Cause: Payments to potentially ineligible beneficiaries were likely due to the large volume of applications processed by the contractor required in a short amount of time. According to Treasury guidelines, the burden of proof of meeting eligibility guidelines is low; therefore, applicants may have provided inaccurate data in order to receive payments under the program. The software system used by the contractor appears to be lacking certain controls that would ensure proper segregation of duties between personnel determining eligibility and personnel reviewing eligibility determinations. Recommendation: We recommend the City continue to investigate questionable cases to determine the validity of the payments made and to quantify the amount of ineligible payments made. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2022-003 Assistance Listing Numbers 97.024 Emergency Food and Shelter National Board Program Federal Agency U.S. Department of Homeland Security Pass-through Agency Not Applicable Award Numbers / Years 2022 City Departments Office of Budget and Management Criteria: The Funding Guidance provided to the City by the Federal Emergency Management Agency states that the program does not allow the use of indirect cost rates. Administrative costs that support relief services are allowable. Limitations on the allowability of expenditures under federal programs apply to both the City as the direct recipient as well as any subrecipients awarded program funds by the City. Condition/Context: The transactions selected in our sample consisted of reimbursements to subrecipients. One of the five sampled transactions was for administrative costs charged to the program utilizing a percentage of direct costs rather than identifying specific administrative costs that support relief services. Our sample was not statistically valid. Effect: Unallowable costs may have been charged to the program by the City via its subrecipient agreements. Questioned Costs: Known questioned costs for ALN 97.024 consist of unsupported administrative cost reimbursements made to subrecipients in the amount of $230,902. Cause: City personnel responsible for administering the award did not prohibit subrecipients from including administrative costs charged as a percentage of direct costs in the program expenditures presented in their vouchers. Recommendation: We recommend the City determine the amount of ineligible administrative costs charged to the City and determine if the funds should be returned to the federal government or if they can be used to provide additional services under the program. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2022-004 Assistance Listing Numbers 97.024 Emergency Food and Shelter National Board Program Federal Agency U.S. Department of Homeland Security Pass-through Agency Not Applicable Award Numbers / Years 2022 City Departments Office of Budget and Management Criteria: According to 2 CFR 200.332, all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and include specific award identification data as detailed in the Uniform Guidance. Condition/Context: Both of the subaward agreements tested did not contain the assistance listing number, federal award identification number, federal award date, and unique entity identifier in the original agreement. The grant agreement said that information would be forthcoming, however, no additional communications were provided to the subrecipients with this information. Our sample was not statistically valid. Effect: Subrecipients may not receive the appropriate subaward information. Questioned Costs: None noted. Cause: At the time the subawards were awarded to the subrecipeints, the missing award information was not known by the City. Subsequently, there was not a process to ensure the required information was provided once it became available. Recommendation: We recommend that the City provide the subrecipients with the appropriate award identification information. In addition, the City should consider whether a procedure is needed to revisit awards periodically to ensure that all required information has been provided to its subrecipients. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2022-002 Assistance Listing Number 21.023 COVID-19 Emergency Rental Assistance Program Federal Agency U.S. Department of Treasury Pass-through Agency Not applicable Award Numbers / Years 2022 City Departments Department of Housing Criteria: According to Treasury guidance, recipients of the Emergency Rental Assistance Program (ERAP) are expected to develop guidelines for determining eligibility of beneficiaries. The City contracted with a local agency to make eligibility determinations and authorize the related payments to beneficiaries based on the guidelines established by the City. The City purchased a software program to assist in the record-keeping and documentation of the case management process from intake to eligibility determinations to payment authorization. Condition/Context: After conducting an extensive analysis of payments made under ERAP, the City has determined that there are potential unallowable payments that were made to ineligible beneficiaries. In addition, the City noted that some eligibility determinations were made and approved by the same person employed by the contractor, resulting in a lack of internal controls over the process. The City is in the process of investigating the validity and extent of potential unallowable payments made. In a sample of 60 benefit payments made, we noted 8 instances where the eligibility determination was approved by the same person who made the determination. Our sample was not statistically valid. Effect: It is possible that program payments were made to ineligible participants. Questioned Costs: Questioned costs cannot be determined at this time. Cause: Payments to potentially ineligible beneficiaries were likely due to the large volume of applications processed by the contractor required in a short amount of time. According to Treasury guidelines, the burden of proof of meeting eligibility guidelines is low; therefore, applicants may have provided inaccurate data in order to receive payments under the program. The software system used by the contractor appears to be lacking certain controls that would ensure proper segregation of duties between personnel determining eligibility and personnel reviewing eligibility determinations. Recommendation: We recommend the City continue to investigate questionable cases to determine the validity of the payments made and to quantify the amount of ineligible payments made. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2022-002 Assistance Listing Number 21.023 COVID-19 Emergency Rental Assistance Program Federal Agency U.S. Department of Treasury Pass-through Agency Not applicable Award Numbers / Years 2022 City Departments Department of Housing Criteria: According to Treasury guidance, recipients of the Emergency Rental Assistance Program (ERAP) are expected to develop guidelines for determining eligibility of beneficiaries. The City contracted with a local agency to make eligibility determinations and authorize the related payments to beneficiaries based on the guidelines established by the City. The City purchased a software program to assist in the record-keeping and documentation of the case management process from intake to eligibility determinations to payment authorization. Condition/Context: After conducting an extensive analysis of payments made under ERAP, the City has determined that there are potential unallowable payments that were made to ineligible beneficiaries. In addition, the City noted that some eligibility determinations were made and approved by the same person employed by the contractor, resulting in a lack of internal controls over the process. The City is in the process of investigating the validity and extent of potential unallowable payments made. In a sample of 60 benefit payments made, we noted 8 instances where the eligibility determination was approved by the same person who made the determination. Our sample was not statistically valid. Effect: It is possible that program payments were made to ineligible participants. Questioned Costs: Questioned costs cannot be determined at this time. Cause: Payments to potentially ineligible beneficiaries were likely due to the large volume of applications processed by the contractor required in a short amount of time. According to Treasury guidelines, the burden of proof of meeting eligibility guidelines is low; therefore, applicants may have provided inaccurate data in order to receive payments under the program. The software system used by the contractor appears to be lacking certain controls that would ensure proper segregation of duties between personnel determining eligibility and personnel reviewing eligibility determinations. Recommendation: We recommend the City continue to investigate questionable cases to determine the validity of the payments made and to quantify the amount of ineligible payments made. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2022-003 Assistance Listing Numbers 97.024 Emergency Food and Shelter National Board Program Federal Agency U.S. Department of Homeland Security Pass-through Agency Not Applicable Award Numbers / Years 2022 City Departments Office of Budget and Management Criteria: The Funding Guidance provided to the City by the Federal Emergency Management Agency states that the program does not allow the use of indirect cost rates. Administrative costs that support relief services are allowable. Limitations on the allowability of expenditures under federal programs apply to both the City as the direct recipient as well as any subrecipients awarded program funds by the City. Condition/Context: The transactions selected in our sample consisted of reimbursements to subrecipients. One of the five sampled transactions was for administrative costs charged to the program utilizing a percentage of direct costs rather than identifying specific administrative costs that support relief services. Our sample was not statistically valid. Effect: Unallowable costs may have been charged to the program by the City via its subrecipient agreements. Questioned Costs: Known questioned costs for ALN 97.024 consist of unsupported administrative cost reimbursements made to subrecipients in the amount of $230,902. Cause: City personnel responsible for administering the award did not prohibit subrecipients from including administrative costs charged as a percentage of direct costs in the program expenditures presented in their vouchers. Recommendation: We recommend the City determine the amount of ineligible administrative costs charged to the City and determine if the funds should be returned to the federal government or if they can be used to provide additional services under the program. Views of Responsible Officials: See Corrective Action Plan.
FINDING 2022-004 Assistance Listing Numbers 97.024 Emergency Food and Shelter National Board Program Federal Agency U.S. Department of Homeland Security Pass-through Agency Not Applicable Award Numbers / Years 2022 City Departments Office of Budget and Management Criteria: According to 2 CFR 200.332, all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and include specific award identification data as detailed in the Uniform Guidance. Condition/Context: Both of the subaward agreements tested did not contain the assistance listing number, federal award identification number, federal award date, and unique entity identifier in the original agreement. The grant agreement said that information would be forthcoming, however, no additional communications were provided to the subrecipients with this information. Our sample was not statistically valid. Effect: Subrecipients may not receive the appropriate subaward information. Questioned Costs: None noted. Cause: At the time the subawards were awarded to the subrecipeints, the missing award information was not known by the City. Subsequently, there was not a process to ensure the required information was provided once it became available. Recommendation: We recommend that the City provide the subrecipients with the appropriate award identification information. In addition, the City should consider whether a procedure is needed to revisit awards periodically to ensure that all required information has been provided to its subrecipients. Views of Responsible Officials: See Corrective Action Plan.