Finding Reference Number: SA2022-001 Suspension and Debarment Documentation for Contracts and Subcontracts Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federal Award Identification Number: SLFRP0424 Criteria: The award terms and conditions of the Coronavirus State and Local Fiscal Recovery Funds agreement with the Department of the Treasury requires that the City comply with OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement), 2 C.F.R. Part 180, including the requirement to include a term or condition in all lower tier covered transactions (contracts and subcontracts described in 2 C.F.R. Part 180, subpart B) that the award is subject to 2 C.F.R. Part 180 and Treasury?s implementing regulation at 31 C.F.R. Part 19. In addition, the OMB Compliance Supplement for the Program requires that prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300. Condition: We selected two contracts for testing and noted that City did not include a term or condition related to compliance with debarment and suspension compliance provisions and we understand that the City did not verify the contractors and subrecipient were not suspended, debarred, or otherwise excluded prior to entering into the agreements. We did note that as of March 28, 2023, the two vendors were not included on the exclusions list on SAM.gov. Cause: We understand that due to turnover in staffing, the City was not able to provide support showing that the City was in compliance with the requirement to verify the status of contractors prior to entering into agreements with the entities. Effect: The City is not in compliance with the award terms and conditions and the OMB Compliance Supplement requirements of the Coronavirus State and Local Fiscal Recovery Funds program. Recommendation: The City should develop procedures to ensure compliance with debarment and suspension provisions of the grant award terms and conditions and the OMB Compliance Supplement of the Coronavirus State and Local Fiscal Recovery Funds program. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.
Finding Reference Number: SA2022-002 - Federal Funding Accountability and Transparency Act (FFATA) Reporting Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-21-MC-06-0009 COVID-19 ? BC-20-MW-06-0009 Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252 that are codified in 2 CFR Part 170, direct recipients of grants are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Subawards that are entered into the FSRS System should be maintained so that any amendments to the subawards are also reflected in the system. Condition: We noted that the City had two subawards during fiscal year 2022 that were than $30,000, but City staff was not able to provide documentation that the subawards were reported in the FSRS. Cause: We understand that program staff were not familiar with the FFATA reporting requirements. Effect: The City is not in compliance with the FFATA reporting requirements. Recommendation: The City should review all first-tier subaward agreements of $30,000 or more to ensure that FFATA reporting is completed. In addition, the City should develop procedures to ensure that FFATA reporting is accurate at all times and reflects any contract amendments and final subaward funding amounts. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.
Finding Reference Number: SA2022-003 - Financial Reporting and Retention of Grant Documentation Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-21-MC-06-0009 COVID-19 ? BC-20-MW-06-0009 Criteria: Grantees may include reports generated by Integrated Disbursement and Information System (IDIS) as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. The reports to be included in the annual performance and evaluation report include the PR26 ? CDBG Financial Summary Report and the PR26 ? CDBG-CV Financial Summary Report. The reports should include accurate information and reconcile to the amounts reported on the SEFA. In addition, one component of the PR26 ? CDBG Financial Summary Report (line 02) and the PR26 ? CDBG-CV Financial Summary Report (line 01) is the grant award amount. That information is directly from the City?s annual Funding Approval/Agreement. Condition: We obtained the City?s PR26 ? CDBG Financial Summary Report for program year 2021 (fiscal year ended June 30, 2022), which reported program expenditures of $1,927,639. We requested a reconciliation of that amount on the PR26 to the program expenditures reported on the SEFA of $963,820, but City staff could not reconcile the amounts reported. It appears that the program expenditures in the PR26 ? CDBG Financial Summary Report were doubled, as the amount on the SEFA is exactly half of that amount. We were not able to test the components of the PR26 ? CDBG-CV Financial Summary Report for fiscal year 2022, because City staff did not retain a copy of the report and was not able to extract a copy from the Integrated Disbursement and Information System (IDIS). Finally, City staff was not able to locate copies of the Funding/Approval Agreements for CDBG and CDBG-CV for the periods starting July 1, 2021 and June 30, 2020, respectively. Those Agreements not only contain the grant award amount, they include special award terms and conditions. Cause: We understand that City staff had worked with the grantor to make corrections to the PR26 ? CDBG Financial Summary Report, but could not provide us with documentation to show that the corrections made were related to the program expenditures. For the PR26 ? CDBG-CV Financial Summary Report, we understand City staff did not retain a copy of the report and were unable to generate a copy of the report from the IDIS system. For the Funding/Approval Agreements, due to staff turnover, City staff could not locate copies of the award agreements. Effect: The City is not in compliance with the financial reporting requirements of the CDBG Program and may not be in compliance with special award terms and conditions of the program. Recommendation: The City should develop procedures to ensure that financial reports filed in the IDIS system reconcile with general ledger activity and amounts reported on the SEFA. The City should also ensure that grant reports and grant award information is retained in the City?s files. Finally, the City should obtain copies of the Funding/Approval Agreements for the program to ensure that it is aware of all special award terms and conditions. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.
Finding Reference Number: SA2022-002 - Federal Funding Accountability and Transparency Act (FFATA) Reporting Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-21-MC-06-0009 COVID-19 ? BC-20-MW-06-0009 Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252 that are codified in 2 CFR Part 170, direct recipients of grants are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Subawards that are entered into the FSRS System should be maintained so that any amendments to the subawards are also reflected in the system. Condition: We noted that the City had two subawards during fiscal year 2022 that were than $30,000, but City staff was not able to provide documentation that the subawards were reported in the FSRS. Cause: We understand that program staff were not familiar with the FFATA reporting requirements. Effect: The City is not in compliance with the FFATA reporting requirements. Recommendation: The City should review all first-tier subaward agreements of $30,000 or more to ensure that FFATA reporting is completed. In addition, the City should develop procedures to ensure that FFATA reporting is accurate at all times and reflects any contract amendments and final subaward funding amounts. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.
Finding Reference Number: SA2022-003 - Financial Reporting and Retention of Grant Documentation Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-21-MC-06-0009 COVID-19 ? BC-20-MW-06-0009 Criteria: Grantees may include reports generated by Integrated Disbursement and Information System (IDIS) as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. The reports to be included in the annual performance and evaluation report include the PR26 ? CDBG Financial Summary Report and the PR26 ? CDBG-CV Financial Summary Report. The reports should include accurate information and reconcile to the amounts reported on the SEFA. In addition, one component of the PR26 ? CDBG Financial Summary Report (line 02) and the PR26 ? CDBG-CV Financial Summary Report (line 01) is the grant award amount. That information is directly from the City?s annual Funding Approval/Agreement. Condition: We obtained the City?s PR26 ? CDBG Financial Summary Report for program year 2021 (fiscal year ended June 30, 2022), which reported program expenditures of $1,927,639. We requested a reconciliation of that amount on the PR26 to the program expenditures reported on the SEFA of $963,820, but City staff could not reconcile the amounts reported. It appears that the program expenditures in the PR26 ? CDBG Financial Summary Report were doubled, as the amount on the SEFA is exactly half of that amount. We were not able to test the components of the PR26 ? CDBG-CV Financial Summary Report for fiscal year 2022, because City staff did not retain a copy of the report and was not able to extract a copy from the Integrated Disbursement and Information System (IDIS). Finally, City staff was not able to locate copies of the Funding/Approval Agreements for CDBG and CDBG-CV for the periods starting July 1, 2021 and June 30, 2020, respectively. Those Agreements not only contain the grant award amount, they include special award terms and conditions. Cause: We understand that City staff had worked with the grantor to make corrections to the PR26 ? CDBG Financial Summary Report, but could not provide us with documentation to show that the corrections made were related to the program expenditures. For the PR26 ? CDBG-CV Financial Summary Report, we understand City staff did not retain a copy of the report and were unable to generate a copy of the report from the IDIS system. For the Funding/Approval Agreements, due to staff turnover, City staff could not locate copies of the award agreements. Effect: The City is not in compliance with the financial reporting requirements of the CDBG Program and may not be in compliance with special award terms and conditions of the program. Recommendation: The City should develop procedures to ensure that financial reports filed in the IDIS system reconcile with general ledger activity and amounts reported on the SEFA. The City should also ensure that grant reports and grant award information is retained in the City?s files. Finally, the City should obtain copies of the Funding/Approval Agreements for the program to ensure that it is aware of all special award terms and conditions. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.
Finding Reference Number: SA2022-001 Suspension and Debarment Documentation for Contracts and Subcontracts Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federal Award Identification Number: SLFRP0424 Criteria: The award terms and conditions of the Coronavirus State and Local Fiscal Recovery Funds agreement with the Department of the Treasury requires that the City comply with OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement), 2 C.F.R. Part 180, including the requirement to include a term or condition in all lower tier covered transactions (contracts and subcontracts described in 2 C.F.R. Part 180, subpart B) that the award is subject to 2 C.F.R. Part 180 and Treasury?s implementing regulation at 31 C.F.R. Part 19. In addition, the OMB Compliance Supplement for the Program requires that prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300. Condition: We selected two contracts for testing and noted that City did not include a term or condition related to compliance with debarment and suspension compliance provisions and we understand that the City did not verify the contractors and subrecipient were not suspended, debarred, or otherwise excluded prior to entering into the agreements. We did note that as of March 28, 2023, the two vendors were not included on the exclusions list on SAM.gov. Cause: We understand that due to turnover in staffing, the City was not able to provide support showing that the City was in compliance with the requirement to verify the status of contractors prior to entering into agreements with the entities. Effect: The City is not in compliance with the award terms and conditions and the OMB Compliance Supplement requirements of the Coronavirus State and Local Fiscal Recovery Funds program. Recommendation: The City should develop procedures to ensure compliance with debarment and suspension provisions of the grant award terms and conditions and the OMB Compliance Supplement of the Coronavirus State and Local Fiscal Recovery Funds program. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.
Finding Reference Number: SA2022-002 - Federal Funding Accountability and Transparency Act (FFATA) Reporting Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-21-MC-06-0009 COVID-19 ? BC-20-MW-06-0009 Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252 that are codified in 2 CFR Part 170, direct recipients of grants are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Subawards that are entered into the FSRS System should be maintained so that any amendments to the subawards are also reflected in the system. Condition: We noted that the City had two subawards during fiscal year 2022 that were than $30,000, but City staff was not able to provide documentation that the subawards were reported in the FSRS. Cause: We understand that program staff were not familiar with the FFATA reporting requirements. Effect: The City is not in compliance with the FFATA reporting requirements. Recommendation: The City should review all first-tier subaward agreements of $30,000 or more to ensure that FFATA reporting is completed. In addition, the City should develop procedures to ensure that FFATA reporting is accurate at all times and reflects any contract amendments and final subaward funding amounts. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.
Finding Reference Number: SA2022-003 - Financial Reporting and Retention of Grant Documentation Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-21-MC-06-0009 COVID-19 ? BC-20-MW-06-0009 Criteria: Grantees may include reports generated by Integrated Disbursement and Information System (IDIS) as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. The reports to be included in the annual performance and evaluation report include the PR26 ? CDBG Financial Summary Report and the PR26 ? CDBG-CV Financial Summary Report. The reports should include accurate information and reconcile to the amounts reported on the SEFA. In addition, one component of the PR26 ? CDBG Financial Summary Report (line 02) and the PR26 ? CDBG-CV Financial Summary Report (line 01) is the grant award amount. That information is directly from the City?s annual Funding Approval/Agreement. Condition: We obtained the City?s PR26 ? CDBG Financial Summary Report for program year 2021 (fiscal year ended June 30, 2022), which reported program expenditures of $1,927,639. We requested a reconciliation of that amount on the PR26 to the program expenditures reported on the SEFA of $963,820, but City staff could not reconcile the amounts reported. It appears that the program expenditures in the PR26 ? CDBG Financial Summary Report were doubled, as the amount on the SEFA is exactly half of that amount. We were not able to test the components of the PR26 ? CDBG-CV Financial Summary Report for fiscal year 2022, because City staff did not retain a copy of the report and was not able to extract a copy from the Integrated Disbursement and Information System (IDIS). Finally, City staff was not able to locate copies of the Funding/Approval Agreements for CDBG and CDBG-CV for the periods starting July 1, 2021 and June 30, 2020, respectively. Those Agreements not only contain the grant award amount, they include special award terms and conditions. Cause: We understand that City staff had worked with the grantor to make corrections to the PR26 ? CDBG Financial Summary Report, but could not provide us with documentation to show that the corrections made were related to the program expenditures. For the PR26 ? CDBG-CV Financial Summary Report, we understand City staff did not retain a copy of the report and were unable to generate a copy of the report from the IDIS system. For the Funding/Approval Agreements, due to staff turnover, City staff could not locate copies of the award agreements. Effect: The City is not in compliance with the financial reporting requirements of the CDBG Program and may not be in compliance with special award terms and conditions of the program. Recommendation: The City should develop procedures to ensure that financial reports filed in the IDIS system reconcile with general ledger activity and amounts reported on the SEFA. The City should also ensure that grant reports and grant award information is retained in the City?s files. Finally, the City should obtain copies of the Funding/Approval Agreements for the program to ensure that it is aware of all special award terms and conditions. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.
Finding Reference Number: SA2022-002 - Federal Funding Accountability and Transparency Act (FFATA) Reporting Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-21-MC-06-0009 COVID-19 ? BC-20-MW-06-0009 Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252 that are codified in 2 CFR Part 170, direct recipients of grants are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Subawards that are entered into the FSRS System should be maintained so that any amendments to the subawards are also reflected in the system. Condition: We noted that the City had two subawards during fiscal year 2022 that were than $30,000, but City staff was not able to provide documentation that the subawards were reported in the FSRS. Cause: We understand that program staff were not familiar with the FFATA reporting requirements. Effect: The City is not in compliance with the FFATA reporting requirements. Recommendation: The City should review all first-tier subaward agreements of $30,000 or more to ensure that FFATA reporting is completed. In addition, the City should develop procedures to ensure that FFATA reporting is accurate at all times and reflects any contract amendments and final subaward funding amounts. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.
Finding Reference Number: SA2022-003 - Financial Reporting and Retention of Grant Documentation Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-21-MC-06-0009 COVID-19 ? BC-20-MW-06-0009 Criteria: Grantees may include reports generated by Integrated Disbursement and Information System (IDIS) as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. The reports to be included in the annual performance and evaluation report include the PR26 ? CDBG Financial Summary Report and the PR26 ? CDBG-CV Financial Summary Report. The reports should include accurate information and reconcile to the amounts reported on the SEFA. In addition, one component of the PR26 ? CDBG Financial Summary Report (line 02) and the PR26 ? CDBG-CV Financial Summary Report (line 01) is the grant award amount. That information is directly from the City?s annual Funding Approval/Agreement. Condition: We obtained the City?s PR26 ? CDBG Financial Summary Report for program year 2021 (fiscal year ended June 30, 2022), which reported program expenditures of $1,927,639. We requested a reconciliation of that amount on the PR26 to the program expenditures reported on the SEFA of $963,820, but City staff could not reconcile the amounts reported. It appears that the program expenditures in the PR26 ? CDBG Financial Summary Report were doubled, as the amount on the SEFA is exactly half of that amount. We were not able to test the components of the PR26 ? CDBG-CV Financial Summary Report for fiscal year 2022, because City staff did not retain a copy of the report and was not able to extract a copy from the Integrated Disbursement and Information System (IDIS). Finally, City staff was not able to locate copies of the Funding/Approval Agreements for CDBG and CDBG-CV for the periods starting July 1, 2021 and June 30, 2020, respectively. Those Agreements not only contain the grant award amount, they include special award terms and conditions. Cause: We understand that City staff had worked with the grantor to make corrections to the PR26 ? CDBG Financial Summary Report, but could not provide us with documentation to show that the corrections made were related to the program expenditures. For the PR26 ? CDBG-CV Financial Summary Report, we understand City staff did not retain a copy of the report and were unable to generate a copy of the report from the IDIS system. For the Funding/Approval Agreements, due to staff turnover, City staff could not locate copies of the award agreements. Effect: The City is not in compliance with the financial reporting requirements of the CDBG Program and may not be in compliance with special award terms and conditions of the program. Recommendation: The City should develop procedures to ensure that financial reports filed in the IDIS system reconcile with general ledger activity and amounts reported on the SEFA. The City should also ensure that grant reports and grant award information is retained in the City?s files. Finally, the City should obtain copies of the Funding/Approval Agreements for the program to ensure that it is aware of all special award terms and conditions. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.