Assistance Listing Number, Federal Agency, and Program Name - ALN 14.218, Department of Housing and Urban Development, CDBG Entitlement Grants Cluster - Community Development Block Grants Cluster
Federal Award Identification Number and Year - B-22-MC-26-0006, B-21-MC-26-0006, B- 20-MW-26-006
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes, 2022-014
Criteria - The Federal Funding Accountability and Transparency Act (FFATA), as amended by 6202 of Public La 110-252, requires a prime grant awardee to report its subgrants using the FFATA Subaward reporting System (FSRS) tool. The prime recipient will have until the
end of the month plus one additional month after an award or subaward is obligated to fulfill the reporting requirement.
Condition - During reporting testing, we noted that the City did not file one FFATA report, and there were five untimely submissions.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - The City obligated several subawards throughout the year ended June 30, 2023, and the reports were due at end of the month plus one additional month after the award or subaward was obligated.
The following table summarizes the transactions examined and the noncompliance identified: See the finding 2023-012 in Section III of the Schedule of Findings and Questioned Costs for chart/table
Cause and Effect - The Citys processes did not properly identify the FFATA filing requirements resulting in a lack of filing and delay in filing reports.
Recommendation - We recommend the City implement adequate controls to ensure compliance with FFATA reporting requirements.
Views of Responsible Officials and Corrective Action Plan - The City will review its current FFATA processes and implement additional controls to ensure timely and accurate filings and compliance with reporting requirements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.218, Department of Housing and Urban Development, CDBG Entitlement Grants Cluster - Community Development Block Grants Cluster
Federal Award Identification Number and Year - B-22-MC-26-0006, B-21-MC-26-0006, B- 20-MW-26-006
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes, 2022-014
Criteria - The Federal Funding Accountability and Transparency Act (FFATA), as amended by 6202 of Public La 110-252, requires a prime grant awardee to report its subgrants using the FFATA Subaward reporting System (FSRS) tool. The prime recipient will have until the
end of the month plus one additional month after an award or subaward is obligated to fulfill the reporting requirement.
Condition - During reporting testing, we noted that the City did not file one FFATA report, and there were five untimely submissions.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - The City obligated several subawards throughout the year ended June 30, 2023, and the reports were due at end of the month plus one additional month after the award or subaward was obligated.
The following table summarizes the transactions examined and the noncompliance identified: See the finding 2023-012 in Section III of the Schedule of Findings and Questioned Costs for chart/table
Cause and Effect - The Citys processes did not properly identify the FFATA filing requirements resulting in a lack of filing and delay in filing reports.
Recommendation - We recommend the City implement adequate controls to ensure compliance with FFATA reporting requirements.
Views of Responsible Officials and Corrective Action Plan - The City will review its current FFATA processes and implement additional controls to ensure timely and accurate filings and compliance with reporting requirements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.218, Department of Housing and Urban Development, CDBG Entitlement Grants Cluster - Community Development Block Grants Cluster
Federal Award Identification Number and Year - B-22-MC-26-0006, B-21-MC-26-0006, B- 20-MW-26-006
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes, 2022-014
Criteria - The Federal Funding Accountability and Transparency Act (FFATA), as amended by 6202 of Public La 110-252, requires a prime grant awardee to report its subgrants using the FFATA Subaward reporting System (FSRS) tool. The prime recipient will have until the
end of the month plus one additional month after an award or subaward is obligated to fulfill the reporting requirement.
Condition - During reporting testing, we noted that the City did not file one FFATA report, and there were five untimely submissions.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - The City obligated several subawards throughout the year ended June 30, 2023, and the reports were due at end of the month plus one additional month after the award or subaward was obligated.
The following table summarizes the transactions examined and the noncompliance identified: See the finding 2023-012 in Section III of the Schedule of Findings and Questioned Costs for chart/table
Cause and Effect - The Citys processes did not properly identify the FFATA filing requirements resulting in a lack of filing and delay in filing reports.
Recommendation - We recommend the City implement adequate controls to ensure compliance with FFATA reporting requirements.
Views of Responsible Officials and Corrective Action Plan - The City will review its current FFATA processes and implement additional controls to ensure timely and accurate filings and compliance with reporting requirements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC)
Federal Award Identification Number and Year - 213MI013W5003, 212MI003W1003, program years 2022 and 2023
Pass-through Entity - Michigan Department of Health and Human Services
Finding Type - Material weakness
Repeat Finding - Yes
2022-006
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The City did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - The City entered into an agreement with a contractor to perform eligibility intake for WIC applicants. While the City arranges for the contractor to perform the intake function, the City is fully responsible for the federal compliance for the eligibility determination process. Testing revealed that the contractor's staff performed both initial and secondary reviews during the intake process. Procedures further revealed that the City did not have any control in place to exercise its oversight responsibility of the grant and relied solely on the contractor's eligibility determinations through May 2023.
Cause and Effect - In the current year, the City contracted with a contractor to perform the eligibility intake function and other programmatic decisions for WIC. However, the City did not implement controls to ensure eligibility conclusions reached by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor's procedures to determine participant eligibility, ineligible participants could receive program benefits.
Recommendation - We recommend the City develop oversight procedures to review the work completed by contractors, which pertains to compliance requirements and programmatic decisions, in this case, participant eligibility determination.
Views of Responsible Officials and Planned Corrective Actions - The City has implemented controls to ensure that the Health Department provides oversight over the contractors. A new contract was in place in May, and the Health Department hired a WIC
program director to monitor participant eligibility compliance and ensure policies and procedures are maintained and followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC)
Federal Award Identification Number and Year - 213MI013W5003, 212MI003W1003, program years 2022 and 2023
Pass-through Entity - Michigan Department of Health and Human Services
Finding Type - Material weakness
Repeat Finding - Yes
2022-006
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The City did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - The City entered into an agreement with a contractor to perform eligibility intake for WIC applicants. While the City arranges for the contractor to perform the intake function, the City is fully responsible for the federal compliance for the eligibility determination process. Testing revealed that the contractor's staff performed both initial and secondary reviews during the intake process. Procedures further revealed that the City did not have any control in place to exercise its oversight responsibility of the grant and relied solely on the contractor's eligibility determinations through May 2023.
Cause and Effect - In the current year, the City contracted with a contractor to perform the eligibility intake function and other programmatic decisions for WIC. However, the City did not implement controls to ensure eligibility conclusions reached by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor's procedures to determine participant eligibility, ineligible participants could receive program benefits.
Recommendation - We recommend the City develop oversight procedures to review the work completed by contractors, which pertains to compliance requirements and programmatic decisions, in this case, participant eligibility determination.
Views of Responsible Officials and Planned Corrective Actions - The City has implemented controls to ensure that the Health Department provides oversight over the contractors. A new contract was in place in May, and the Health Department hired a WIC
program director to monitor participant eligibility compliance and ensure policies and procedures are maintained and followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC)
Federal Award Identification Number and Year - 213MI013W5003, 212MI003W1003, program years 2022 and 2023
Pass-through Entity - Michigan Department of Health and Human Services
Finding Type - Material weakness
Repeat Finding - Yes
2022-006
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The City did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - The City entered into an agreement with a contractor to perform eligibility intake for WIC applicants. While the City arranges for the contractor to perform the intake function, the City is fully responsible for the federal compliance for the eligibility determination process. Testing revealed that the contractor's staff performed both initial and secondary reviews during the intake process. Procedures further revealed that the City did not have any control in place to exercise its oversight responsibility of the grant and relied solely on the contractor's eligibility determinations through May 2023.
Cause and Effect - In the current year, the City contracted with a contractor to perform the eligibility intake function and other programmatic decisions for WIC. However, the City did not implement controls to ensure eligibility conclusions reached by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor's procedures to determine participant eligibility, ineligible participants could receive program benefits.
Recommendation - We recommend the City develop oversight procedures to review the work completed by contractors, which pertains to compliance requirements and programmatic decisions, in this case, participant eligibility determination.
Views of Responsible Officials and Planned Corrective Actions - The City has implemented controls to ensure that the Health Department provides oversight over the contractors. A new contract was in place in May, and the Health Department hired a WIC
program director to monitor participant eligibility compliance and ensure policies and procedures are maintained and followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC)
Federal Award Identification Number and Year - 213MI013W5003, 212MI003W1003, program years 2022 and 2023
Pass-through Entity - Michigan Department of Health and Human Services
Finding Type - Material weakness
Repeat Finding - Yes
2022-006
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The City did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - The City entered into an agreement with a contractor to perform eligibility intake for WIC applicants. While the City arranges for the contractor to perform the intake function, the City is fully responsible for the federal compliance for the eligibility determination process. Testing revealed that the contractor's staff performed both initial and secondary reviews during the intake process. Procedures further revealed that the City did not have any control in place to exercise its oversight responsibility of the grant and relied solely on the contractor's eligibility determinations through May 2023.
Cause and Effect - In the current year, the City contracted with a contractor to perform the eligibility intake function and other programmatic decisions for WIC. However, the City did not implement controls to ensure eligibility conclusions reached by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor's procedures to determine participant eligibility, ineligible participants could receive program benefits.
Recommendation - We recommend the City develop oversight procedures to review the work completed by contractors, which pertains to compliance requirements and programmatic decisions, in this case, participant eligibility determination.
Views of Responsible Officials and Planned Corrective Actions - The City has implemented controls to ensure that the Health Department provides oversight over the contractors. A new contract was in place in May, and the Health Department hired a WIC
program director to monitor participant eligibility compliance and ensure policies and procedures are maintained and followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC)
Federal Award Identification Number and Year - 213MI013W5003, 212MI003W1003, program years 2022 and 2023
Pass-through Entity - Michigan Department of Health and Human Services
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a nonfederal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end of the period of
performance, as specified in the terms and conditions of the federal award. However, as outlined within the grant award from the Michigan Department of Health and Human Services and more restrictive than 2 CFR 200.344(b), the City must liquidate within 60 days after the State's fiscal year end any unpaid year-end commitments and obligations. Any obligation remaining unliquidated after 60 days from the end of the period shall revert to the State for disposition in accordance with applicable state and/or federal requirements, except as specifically authorized in writing by the department.
Condition - The City did not have adequate controls in place to ensure obligations were liquidated (paid) within the required 60 days.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Refer to context below.
Context - Testing revealed 3 invoices out of 25 were liquidated after the required 60 days for the performance period ended September 30, 2022. Based on email communication received by the City from the Michigan Department of Health and Human Services, the department granted the City retroactive approval to allow for the expenses despite being liquidated after the 60-day period. As a result, no questioned costs are reported.
Cause and Effect - Failure to comply with the terms and conditions of the grant agreement, including the liquidation provisions, may result in disallowed costs and the need to repay the funder for such costs.
Recommendation - We recommend the City ensure controls are in place to comply with liquidation requirements outlined in the award agreements and/or Uniform Guidance issued by 0MB (whichever is more restrictive).
Views of Responsible Officials and Planned Corrective Actions - The OCFO will work with the Health Department to implement additional controls to ensure all subrecipients and contractors submit invoices timely and that they are reviewed, approved, and processed for
payment prior to the 60-day liquidation requirement period.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC)
Federal Award Identification Number and Year - 213MI013W5003, 212MI003W1003, program years 2022 and 2023
Pass-through Entity - Michigan Department of Health and Human Services
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a nonfederal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end of the period of
performance, as specified in the terms and conditions of the federal award. However, as outlined within the grant award from the Michigan Department of Health and Human Services and more restrictive than 2 CFR 200.344(b), the City must liquidate within 60 days after the State's fiscal year end any unpaid year-end commitments and obligations. Any obligation remaining unliquidated after 60 days from the end of the period shall revert to the State for disposition in accordance with applicable state and/or federal requirements, except as specifically authorized in writing by the department.
Condition - The City did not have adequate controls in place to ensure obligations were liquidated (paid) within the required 60 days.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Refer to context below.
Context - Testing revealed 3 invoices out of 25 were liquidated after the required 60 days for the performance period ended September 30, 2022. Based on email communication received by the City from the Michigan Department of Health and Human Services, the department granted the City retroactive approval to allow for the expenses despite being liquidated after the 60-day period. As a result, no questioned costs are reported.
Cause and Effect - Failure to comply with the terms and conditions of the grant agreement, including the liquidation provisions, may result in disallowed costs and the need to repay the funder for such costs.
Recommendation - We recommend the City ensure controls are in place to comply with liquidation requirements outlined in the award agreements and/or Uniform Guidance issued by 0MB (whichever is more restrictive).
Views of Responsible Officials and Planned Corrective Actions - The OCFO will work with the Health Department to implement additional controls to ensure all subrecipients and contractors submit invoices timely and that they are reviewed, approved, and processed for
payment prior to the 60-day liquidation requirement period.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC)
Federal Award Identification Number and Year - 213MI013W5003, 212MI003W1003, program years 2022 and 2023
Pass-through Entity - Michigan Department of Health and Human Services
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a nonfederal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end of the period of
performance, as specified in the terms and conditions of the federal award. However, as outlined within the grant award from the Michigan Department of Health and Human Services and more restrictive than 2 CFR 200.344(b), the City must liquidate within 60 days after the State's fiscal year end any unpaid year-end commitments and obligations. Any obligation remaining unliquidated after 60 days from the end of the period shall revert to the State for disposition in accordance with applicable state and/or federal requirements, except as specifically authorized in writing by the department.
Condition - The City did not have adequate controls in place to ensure obligations were liquidated (paid) within the required 60 days.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Refer to context below.
Context - Testing revealed 3 invoices out of 25 were liquidated after the required 60 days for the performance period ended September 30, 2022. Based on email communication received by the City from the Michigan Department of Health and Human Services, the department granted the City retroactive approval to allow for the expenses despite being liquidated after the 60-day period. As a result, no questioned costs are reported.
Cause and Effect - Failure to comply with the terms and conditions of the grant agreement, including the liquidation provisions, may result in disallowed costs and the need to repay the funder for such costs.
Recommendation - We recommend the City ensure controls are in place to comply with liquidation requirements outlined in the award agreements and/or Uniform Guidance issued by 0MB (whichever is more restrictive).
Views of Responsible Officials and Planned Corrective Actions - The OCFO will work with the Health Department to implement additional controls to ensure all subrecipients and contractors submit invoices timely and that they are reviewed, approved, and processed for
payment prior to the 60-day liquidation requirement period.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC)
Federal Award Identification Number and Year - 213MI013W5003, 212MI003W1003, program years 2022 and 2023
Pass-through Entity - Michigan Department of Health and Human Services
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a nonfederal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end of the period of
performance, as specified in the terms and conditions of the federal award. However, as outlined within the grant award from the Michigan Department of Health and Human Services and more restrictive than 2 CFR 200.344(b), the City must liquidate within 60 days after the State's fiscal year end any unpaid year-end commitments and obligations. Any obligation remaining unliquidated after 60 days from the end of the period shall revert to the State for disposition in accordance with applicable state and/or federal requirements, except as specifically authorized in writing by the department.
Condition - The City did not have adequate controls in place to ensure obligations were liquidated (paid) within the required 60 days.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Refer to context below.
Context - Testing revealed 3 invoices out of 25 were liquidated after the required 60 days for the performance period ended September 30, 2022. Based on email communication received by the City from the Michigan Department of Health and Human Services, the department granted the City retroactive approval to allow for the expenses despite being liquidated after the 60-day period. As a result, no questioned costs are reported.
Cause and Effect - Failure to comply with the terms and conditions of the grant agreement, including the liquidation provisions, may result in disallowed costs and the need to repay the funder for such costs.
Recommendation - We recommend the City ensure controls are in place to comply with liquidation requirements outlined in the award agreements and/or Uniform Guidance issued by 0MB (whichever is more restrictive).
Views of Responsible Officials and Planned Corrective Actions - The OCFO will work with the Health Department to implement additional controls to ensure all subrecipients and contractors submit invoices timely and that they are reviewed, approved, and processed for
payment prior to the 60-day liquidation requirement period.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507, Department of Transportation, Federal Transit Cluster - Federal Transit Formula Grants
Federal Award Identification Number and Year - Ml-2022-026-00, program year 2022
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The City did not have adequate controls in place to ensure payroll costs charged to the program were accurate in relation to underlying payroll records.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Refer to context below.
Context - Testing revealed approximately $141,000 in credit adjustments was incorrectly excluded from a $14,419,000 adjusting journal entry to increase payroll costs charged to the program during the fiscal period under audit.
The pool of gross payroll costs identified by the City for allocation to the grant under the final adjusting journal entry, which includes the costs described in the preceding paragraph, totaled approximately $20,932,000. However, the City only allocated approximately $18,620,000 of these gross payroll costs to the grant to align with the budgeted use of the funds for the fiscal period. The City in essence had $20,791,000 of eligible expenses, after accounting for the approximately $141,000 of credit adjustments, to expend the remaining $14,419,000 award amount. The City did not specifically identify which transactions within the payroll cost population were not ultimately allocated to the program. After identifying approximately $4,201,000 of payroll already charged to the program through the City's usual biweekly payroll process, the City's internal control procedures did not include a verification process to ensure that the payroll records used to develop the $14,419,000 adjusting entry to true up payroll costs agreed to underlying payroll records. Given that the City did not need to allocate the entire $20,932,000, the $141,000 overstatement is not considered questioned costs, as there was approximately $2,300,000 of eligible costs not allocated.
Cause and Effect - The lack of controls surrounding the payroll adjustment resulted in payroll costs that were overstated in relation to the underlying payroll register. The lack of controls could result in disallowed costs.
Recommendation - We recommend the City ensure controls are in place to verify the accuracy and completeness of amounts charged to the grant against supporting documentation and underlying records.
Views of Responsible Officials and Planned Corrective Actions - The City will ensure the required controls are in place to help ensure accurate payroll costs are charged to the program and completeness of the supporting documentation.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID-19 HOPWA
Federal Award Identification Number and Year - MIH20-FHW001, MIH20-F001, MIH21- F001, MIH22-F001
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2022-007
Criteria - Per 24 CFR 574.310, except for persons in short-term supportive housing, each person receiving rental assistance under the HOPWA program must pay as rent the higher of (1) 30 percent of the family's monthly adjusted gross income; (2) 10 percent of the family's monthly gross income; or (3) the portion of the payments that is designated if the family is receiving payments for welfare assistance from a public agency and a part of the payments, adjusted in accordance with the family's actual housing costs, that is specifically designated by the agency to meet the family's housing costs.
Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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 the 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).
Condition - In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation and distribution of benefits were identified.
Questioned Costs - $3,022
Identification of How Questioned Costs Were Computed - Questioned costs reflect the gross overpayments. See context below for instances of benefits being overpaid.
Context - During eligibility testing of a sample of 60, we noted the following:
• A lack of effective supervisory review of the annual certification process and calculation of benefits resulted in one instance of benefits being overpaid by $176 and four instances of benefits being underpaid by $221 based on income and family size.
• A lack of effective supervisory review over the distribution of benefits throughout the benefit agreement period resulted in two instances of an overpayment of benefits by $2,846 and one instances of an underpayment of benefits by $10.
Cause and Effect - The lack of adequate controls in the form of detailed reviews over the calculation and payment of rental assistance, based on the requirements of 24 CFR 574.310, resulted in both overpayments and underpayments of rental assistance to beneficiaries.
Recommendation - We recommend the City review its procedures and controls specific to the calculation and distribution of rental assistance and make modifications as necessary to ensure that inputs of the calculation are reviewed for completeness and accuracy and that the payments are consistent with the calculation prior to finalizing the benefit agreements and communicating the same to the participant.
Views of Responsible Officials and Planned Corrective Actions - City of Detroit HOPWA program has a dedicated quality coordinator position. The coordinator will continue to work closely with the HOPWA program team and conduct regular file audits. The HOPWA program team has also implemented additional steps, including the use of eligibility templates to help ensure accurate rental assistance calculations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID-19 HOPWA
Federal Award Identification Number and Year - MIH20-FHW001, MIH20-F001, MIH21- F001, MIH22-F001
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2022-007
Criteria - Per 24 CFR 574.310, except for persons in short-term supportive housing, each person receiving rental assistance under the HOPWA program must pay as rent the higher of (1) 30 percent of the family's monthly adjusted gross income; (2) 10 percent of the family's monthly gross income; or (3) the portion of the payments that is designated if the family is receiving payments for welfare assistance from a public agency and a part of the payments, adjusted in accordance with the family's actual housing costs, that is specifically designated by the agency to meet the family's housing costs.
Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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 the 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).
Condition - In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation and distribution of benefits were identified.
Questioned Costs - $3,022
Identification of How Questioned Costs Were Computed - Questioned costs reflect the gross overpayments. See context below for instances of benefits being overpaid.
Context - During eligibility testing of a sample of 60, we noted the following:
• A lack of effective supervisory review of the annual certification process and calculation of benefits resulted in one instance of benefits being overpaid by $176 and four instances of benefits being underpaid by $221 based on income and family size.
• A lack of effective supervisory review over the distribution of benefits throughout the benefit agreement period resulted in two instances of an overpayment of benefits by $2,846 and one instances of an underpayment of benefits by $10.
Cause and Effect - The lack of adequate controls in the form of detailed reviews over the calculation and payment of rental assistance, based on the requirements of 24 CFR 574.310, resulted in both overpayments and underpayments of rental assistance to beneficiaries.
Recommendation - We recommend the City review its procedures and controls specific to the calculation and distribution of rental assistance and make modifications as necessary to ensure that inputs of the calculation are reviewed for completeness and accuracy and that the payments are consistent with the calculation prior to finalizing the benefit agreements and communicating the same to the participant.
Views of Responsible Officials and Planned Corrective Actions - City of Detroit HOPWA program has a dedicated quality coordinator position. The coordinator will continue to work closely with the HOPWA program team and conduct regular file audits. The HOPWA program team has also implemented additional steps, including the use of eligibility templates to help ensure accurate rental assistance calculations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID-19 HOPWA
Federal Award Identification Number and Year - MIH20-FHW001, MIH20-F001, MIH21- F001, MIH22-F001
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2022-007
Criteria - Per 24 CFR 574.310, except for persons in short-term supportive housing, each person receiving rental assistance under the HOPWA program must pay as rent the higher of (1) 30 percent of the family's monthly adjusted gross income; (2) 10 percent of the family's monthly gross income; or (3) the portion of the payments that is designated if the family is receiving payments for welfare assistance from a public agency and a part of the payments, adjusted in accordance with the family's actual housing costs, that is specifically designated by the agency to meet the family's housing costs.
Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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 the 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).
Condition - In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation and distribution of benefits were identified.
Questioned Costs - $3,022
Identification of How Questioned Costs Were Computed - Questioned costs reflect the gross overpayments. See context below for instances of benefits being overpaid.
Context - During eligibility testing of a sample of 60, we noted the following:
• A lack of effective supervisory review of the annual certification process and calculation of benefits resulted in one instance of benefits being overpaid by $176 and four instances of benefits being underpaid by $221 based on income and family size.
• A lack of effective supervisory review over the distribution of benefits throughout the benefit agreement period resulted in two instances of an overpayment of benefits by $2,846 and one instances of an underpayment of benefits by $10.
Cause and Effect - The lack of adequate controls in the form of detailed reviews over the calculation and payment of rental assistance, based on the requirements of 24 CFR 574.310, resulted in both overpayments and underpayments of rental assistance to beneficiaries.
Recommendation - We recommend the City review its procedures and controls specific to the calculation and distribution of rental assistance and make modifications as necessary to ensure that inputs of the calculation are reviewed for completeness and accuracy and that the payments are consistent with the calculation prior to finalizing the benefit agreements and communicating the same to the participant.
Views of Responsible Officials and Planned Corrective Actions - City of Detroit HOPWA program has a dedicated quality coordinator position. The coordinator will continue to work closely with the HOPWA program team and conduct regular file audits. The HOPWA program team has also implemented additional steps, including the use of eligibility templates to help ensure accurate rental assistance calculations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID-19 HOPWA
Federal Award Identification Number and Year - MIH20-FHW001, MIH20-F001, MIH21- F001, MIH22-F001
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2022-007
Criteria - Per 24 CFR 574.310, except for persons in short-term supportive housing, each person receiving rental assistance under the HOPWA program must pay as rent the higher of (1) 30 percent of the family's monthly adjusted gross income; (2) 10 percent of the family's monthly gross income; or (3) the portion of the payments that is designated if the family is receiving payments for welfare assistance from a public agency and a part of the payments, adjusted in accordance with the family's actual housing costs, that is specifically designated by the agency to meet the family's housing costs.
Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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 the 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).
Condition - In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation and distribution of benefits were identified.
Questioned Costs - $3,022
Identification of How Questioned Costs Were Computed - Questioned costs reflect the gross overpayments. See context below for instances of benefits being overpaid.
Context - During eligibility testing of a sample of 60, we noted the following:
• A lack of effective supervisory review of the annual certification process and calculation of benefits resulted in one instance of benefits being overpaid by $176 and four instances of benefits being underpaid by $221 based on income and family size.
• A lack of effective supervisory review over the distribution of benefits throughout the benefit agreement period resulted in two instances of an overpayment of benefits by $2,846 and one instances of an underpayment of benefits by $10.
Cause and Effect - The lack of adequate controls in the form of detailed reviews over the calculation and payment of rental assistance, based on the requirements of 24 CFR 574.310, resulted in both overpayments and underpayments of rental assistance to beneficiaries.
Recommendation - We recommend the City review its procedures and controls specific to the calculation and distribution of rental assistance and make modifications as necessary to ensure that inputs of the calculation are reviewed for completeness and accuracy and that the payments are consistent with the calculation prior to finalizing the benefit agreements and communicating the same to the participant.
Views of Responsible Officials and Planned Corrective Actions - City of Detroit HOPWA program has a dedicated quality coordinator position. The coordinator will continue to work closely with the HOPWA program team and conduct regular file audits. The HOPWA program team has also implemented additional steps, including the use of eligibility templates to help ensure accurate rental assistance calculations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID-19 HOPWA
Federal Award Identification Number and Year - MIH20-FHW001, MIH20-F001, MIH21- F001, MIH22-F001
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Under 0MB Number 2506-40110-C, on an annual basis, HOPWA formula grantees are required to submit a Consolidated Annual Performance and Evaluation Report (CAPER) demonstrating essential information on grant activities, project sponsors, housing sites, units and households, and beneficiaries. Per 2 CFR 200.302(b), the nonfederal entity must maintain a financial management system that provides records that identify adequately the source and application of funds for federally funded activities.
Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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 the 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).
Condition - The controls in place were not adequate to ensure that amounts reported within the CAPER were accurate and complete in relation to activity reported in the general ledger and underlying records of the City.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Management has a process in place to compile beneficiary headcounts, rental assistance, and other costs for reporting within the CAPER; however, management did not maintain the underlying records to support the amounts and expenditures reported in the
CAPER submitted for program year ended June 30, 2023. Where we were able to perform procedures to reconcile to the beneficiary headcount, we identified approximately $3.9 million of expenditures reported within the CAPER was understated by approximately $300,000 in relation to the amounts reported in the general ledger.
Cause and Effect - Not maintaining the underlying records and supporting documentation may lead to inaccurate information being reported to the funder and could perhaps inappropriately influence subsequent decisions.
Recommendation - We recommend the City implement a system of internal controls to ensure that records used in reporting information to the funding agency are retained in support of the amounts and that supervisory review over those inputs are in place. Additionally, we recommend the City reconcile the books and records timely to ensure accurate and complete reporting of program activity.
Views of Responsible Officials and Planned Corrective Actions - The City will review its current process and implement additional reporting controls, including verification of expenditures, retention of supporting documentation, and a timely final reconciliation of the CAPER to the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID-19 HOPWA
Federal Award Identification Number and Year - MIH20-FHW001, MIH20-F001, MIH21- F001, MIH22-F001
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Under 0MB Number 2506-40110-C, on an annual basis, HOPWA formula grantees are required to submit a Consolidated Annual Performance and Evaluation Report (CAPER) demonstrating essential information on grant activities, project sponsors, housing sites, units and households, and beneficiaries. Per 2 CFR 200.302(b), the nonfederal entity must maintain a financial management system that provides records that identify adequately the source and application of funds for federally funded activities.
Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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 the 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).
Condition - The controls in place were not adequate to ensure that amounts reported within the CAPER were accurate and complete in relation to activity reported in the general ledger and underlying records of the City.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Management has a process in place to compile beneficiary headcounts, rental assistance, and other costs for reporting within the CAPER; however, management did not maintain the underlying records to support the amounts and expenditures reported in the
CAPER submitted for program year ended June 30, 2023. Where we were able to perform procedures to reconcile to the beneficiary headcount, we identified approximately $3.9 million of expenditures reported within the CAPER was understated by approximately $300,000 in relation to the amounts reported in the general ledger.
Cause and Effect - Not maintaining the underlying records and supporting documentation may lead to inaccurate information being reported to the funder and could perhaps inappropriately influence subsequent decisions.
Recommendation - We recommend the City implement a system of internal controls to ensure that records used in reporting information to the funding agency are retained in support of the amounts and that supervisory review over those inputs are in place. Additionally, we recommend the City reconcile the books and records timely to ensure accurate and complete reporting of program activity.
Views of Responsible Officials and Planned Corrective Actions - The City will review its current process and implement additional reporting controls, including verification of expenditures, retention of supporting documentation, and a timely final reconciliation of the CAPER to the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID-19 HOPWA
Federal Award Identification Number and Year - MIH20-FHW001, MIH20-F001, MIH21- F001, MIH22-F001
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Under 0MB Number 2506-40110-C, on an annual basis, HOPWA formula grantees are required to submit a Consolidated Annual Performance and Evaluation Report (CAPER) demonstrating essential information on grant activities, project sponsors, housing sites, units and households, and beneficiaries. Per 2 CFR 200.302(b), the nonfederal entity must maintain a financial management system that provides records that identify adequately the source and application of funds for federally funded activities.
Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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 the 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).
Condition - The controls in place were not adequate to ensure that amounts reported within the CAPER were accurate and complete in relation to activity reported in the general ledger and underlying records of the City.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Management has a process in place to compile beneficiary headcounts, rental assistance, and other costs for reporting within the CAPER; however, management did not maintain the underlying records to support the amounts and expenditures reported in the
CAPER submitted for program year ended June 30, 2023. Where we were able to perform procedures to reconcile to the beneficiary headcount, we identified approximately $3.9 million of expenditures reported within the CAPER was understated by approximately $300,000 in relation to the amounts reported in the general ledger.
Cause and Effect - Not maintaining the underlying records and supporting documentation may lead to inaccurate information being reported to the funder and could perhaps inappropriately influence subsequent decisions.
Recommendation - We recommend the City implement a system of internal controls to ensure that records used in reporting information to the funding agency are retained in support of the amounts and that supervisory review over those inputs are in place. Additionally, we recommend the City reconcile the books and records timely to ensure accurate and complete reporting of program activity.
Views of Responsible Officials and Planned Corrective Actions - The City will review its current process and implement additional reporting controls, including verification of expenditures, retention of supporting documentation, and a timely final reconciliation of the CAPER to the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID-19 HOPWA
Federal Award Identification Number and Year - MIH20-FHW001, MIH20-F001, MIH21- F001, MIH22-F001
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Under 0MB Number 2506-40110-C, on an annual basis, HOPWA formula grantees are required to submit a Consolidated Annual Performance and Evaluation Report (CAPER) demonstrating essential information on grant activities, project sponsors, housing sites, units and households, and beneficiaries. Per 2 CFR 200.302(b), the nonfederal entity must maintain a financial management system that provides records that identify adequately the source and application of funds for federally funded activities.
Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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 the 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).
Condition - The controls in place were not adequate to ensure that amounts reported within the CAPER were accurate and complete in relation to activity reported in the general ledger and underlying records of the City.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Management has a process in place to compile beneficiary headcounts, rental assistance, and other costs for reporting within the CAPER; however, management did not maintain the underlying records to support the amounts and expenditures reported in the
CAPER submitted for program year ended June 30, 2023. Where we were able to perform procedures to reconcile to the beneficiary headcount, we identified approximately $3.9 million of expenditures reported within the CAPER was understated by approximately $300,000 in relation to the amounts reported in the general ledger.
Cause and Effect - Not maintaining the underlying records and supporting documentation may lead to inaccurate information being reported to the funder and could perhaps inappropriately influence subsequent decisions.
Recommendation - We recommend the City implement a system of internal controls to ensure that records used in reporting information to the funding agency are retained in support of the amounts and that supervisory review over those inputs are in place. Additionally, we recommend the City reconcile the books and records timely to ensure accurate and complete reporting of program activity.
Views of Responsible Officials and Planned Corrective Actions - The City will review its current process and implement additional reporting controls, including verification of expenditures, retention of supporting documentation, and a timely final reconciliation of the CAPER to the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 93.914, Department of Health and Human Services, HIV Emergency Relief Project Grants
Federal Award Identification Number and Year - 6 H89HA00021-31-01, 6 H89hA00021 29- 01
Pass-through Entity - N/A
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - Per 45 CFR 75.303(a), a nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The City did not provide a formal report on monitoring performed for 3 of its subrecipients.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - In the case of 3 out of the City's 14 subrecipients that received funding under the above-mentioned award, the City's communication to the subrecipients related to the results of the monitoring was significantly delayed. Communication was sent approximately one year subsequent to the monitoring procedures. Based on the reports, there were no matters noted requiring a corrective action plan from the subrecipients. The reports also did not reveal any questioned costs.
Cause and Effect - There were no controls in place to ensure monitoring results were communicated timely to subrecipients subsequent to a staff member's departure. The lack of timely communication could result in delayed corrective action and possible disallowance of costs.
Recommendation - We recommend the City review its controls to ensure the entire cycle of monitoring, from the planning phase to the close-out phase, is completed in a timely manner.
Views of Responsible Officials and Planned Corrective Actions - The City will review its subrecipient monitoring policy and implement additional controls to ensure an end-to-end monitoring process is in place that includes timely communication of the reports.
Assistance Listing Number, Federal Agency, and Program Name - ALN 93.914, Department of Health and Human Services, HIV Emergency Relief Project Grants
Federal Award Identification Number and Year - 6 H89HA00021-31-01, 6 H89hA00021 29- 01
Pass-through Entity - N/A
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - Per 45 CFR 75.303(a), a nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The City did not provide a formal report on monitoring performed for 3 of its subrecipients.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - In the case of 3 out of the City's 14 subrecipients that received funding under the above-mentioned award, the City's communication to the subrecipients related to the results of the monitoring was significantly delayed. Communication was sent approximately one year subsequent to the monitoring procedures. Based on the reports, there were no matters noted requiring a corrective action plan from the subrecipients. The reports also did not reveal any questioned costs.
Cause and Effect - There were no controls in place to ensure monitoring results were communicated timely to subrecipients subsequent to a staff member's departure. The lack of timely communication could result in delayed corrective action and possible disallowance of costs.
Recommendation - We recommend the City review its controls to ensure the entire cycle of monitoring, from the planning phase to the close-out phase, is completed in a timely manner.
Views of Responsible Officials and Planned Corrective Actions - The City will review its subrecipient monitoring policy and implement additional controls to ensure an end-to-end monitoring process is in place that includes timely communication of the reports.
Assistance Listing Number, Federal Agency, and Program Name - 14.218, Department of Housing and Urban Development, CDBG Entitlement Grants Cluster - Community Development Block Grant/Entitlement Grants (CDBG)
14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With Aids (HOPWA)
14.905, Department of Housing and Urban Development, Lead Hazard Reduction Demonstration Grant Program (Lead)
Federal Award Identification Number and Year -
CDBG - B-22-MC-26-0006
HOPWA - MIH22F001
Lead - MILNG0007-19, and MILHB0682-18
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), nonfederal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Per 2 CFR 200.403(9), costs must be adequately documented.
Condition - The City duplicated costs charged to certain grants.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Refer to context below
Context - In conjunction with the year-end close process, the City manually reviews invoices received subsequent to year end and identifies amounts to be accrued. These amounts are accrued via manual journal entries posted to period 13. As this is a period 13 entry, the amounts automatically reverse in the new year. During this process, the City duplicated costs to be accrued in the amount of $12,300 under ALN 14.218 (CDBG), $327,709 under ALN 14.241 (HOPWA), and $235,911 under ALN 14.905 (Lead). Despite being accrued, the City did not request reimbursement for these costs, as reimbursement is only requested after expenses are paid. Upon identification of the error, the City reduced the amounts reported on the schedule of expenditures of federal awards (SEFA) by the amounts noted above.
Cause and Effect - The City's control regarding the year-end close process did not identify that certain costs accrued were duplicated. As a result, the initial SEFA provided to the auditors was overstated by these costs. The City excluded the duplicate costs from the final
SEFA.
Recommendation - We recommend the City review its processes and controls to ensure that the preparation and review of journal entries to accrue for costs include a review for duplicate costs.
Views of Responsible Officials and Corrective Action Plan - The City will review its journal entry controls and processes to help ensure journal entries are posted accurately and implement a review for duplicate costs.
Assistance Listing Number, Federal Agency, and Program Name - 14.218, Department of Housing and Urban Development, CDBG Entitlement Grants Cluster - Community Development Block Grant/Entitlement Grants (CDBG)
14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With Aids (HOPWA)
14.905, Department of Housing and Urban Development, Lead Hazard Reduction Demonstration Grant Program (Lead)
Federal Award Identification Number and Year -
CDBG - B-22-MC-26-0006
HOPWA - MIH22F001
Lead - MILNG0007-19, and MILHB0682-18
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), nonfederal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Per 2 CFR 200.403(9), costs must be adequately documented.
Condition - The City duplicated costs charged to certain grants.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Refer to context below
Context - In conjunction with the year-end close process, the City manually reviews invoices received subsequent to year end and identifies amounts to be accrued. These amounts are accrued via manual journal entries posted to period 13. As this is a period 13 entry, the amounts automatically reverse in the new year. During this process, the City duplicated costs to be accrued in the amount of $12,300 under ALN 14.218 (CDBG), $327,709 under ALN 14.241 (HOPWA), and $235,911 under ALN 14.905 (Lead). Despite being accrued, the City did not request reimbursement for these costs, as reimbursement is only requested after expenses are paid. Upon identification of the error, the City reduced the amounts reported on the schedule of expenditures of federal awards (SEFA) by the amounts noted above.
Cause and Effect - The City's control regarding the year-end close process did not identify that certain costs accrued were duplicated. As a result, the initial SEFA provided to the auditors was overstated by these costs. The City excluded the duplicate costs from the final
SEFA.
Recommendation - We recommend the City review its processes and controls to ensure that the preparation and review of journal entries to accrue for costs include a review for duplicate costs.
Views of Responsible Officials and Corrective Action Plan - The City will review its journal entry controls and processes to help ensure journal entries are posted accurately and implement a review for duplicate costs.
Assistance Listing Number, Federal Agency, and Program Name - 14.218, Department of Housing and Urban Development, CDBG Entitlement Grants Cluster - Community Development Block Grant/Entitlement Grants (CDBG)
14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With Aids (HOPWA)
14.905, Department of Housing and Urban Development, Lead Hazard Reduction Demonstration Grant Program (Lead)
Federal Award Identification Number and Year -
CDBG - B-22-MC-26-0006
HOPWA - MIH22F001
Lead - MILNG0007-19, and MILHB0682-18
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), nonfederal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Per 2 CFR 200.403(9), costs must be adequately documented.
Condition - The City duplicated costs charged to certain grants.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Refer to context below
Context - In conjunction with the year-end close process, the City manually reviews invoices received subsequent to year end and identifies amounts to be accrued. These amounts are accrued via manual journal entries posted to period 13. As this is a period 13 entry, the amounts automatically reverse in the new year. During this process, the City duplicated costs to be accrued in the amount of $12,300 under ALN 14.218 (CDBG), $327,709 under ALN 14.241 (HOPWA), and $235,911 under ALN 14.905 (Lead). Despite being accrued, the City did not request reimbursement for these costs, as reimbursement is only requested after expenses are paid. Upon identification of the error, the City reduced the amounts reported on the schedule of expenditures of federal awards (SEFA) by the amounts noted above.
Cause and Effect - The City's control regarding the year-end close process did not identify that certain costs accrued were duplicated. As a result, the initial SEFA provided to the auditors was overstated by these costs. The City excluded the duplicate costs from the final
SEFA.
Recommendation - We recommend the City review its processes and controls to ensure that the preparation and review of journal entries to accrue for costs include a review for duplicate costs.
Views of Responsible Officials and Corrective Action Plan - The City will review its journal entry controls and processes to help ensure journal entries are posted accurately and implement a review for duplicate costs.
Assistance Listing Number, Federal Agency, and Program Name - 14.218, Department of Housing and Urban Development, CDBG Entitlement Grants Cluster - Community Development Block Grant/Entitlement Grants (CDBG)
14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With Aids (HOPWA)
14.905, Department of Housing and Urban Development, Lead Hazard Reduction Demonstration Grant Program (Lead)
Federal Award Identification Number and Year -
CDBG - B-22-MC-26-0006
HOPWA - MIH22F001
Lead - MILNG0007-19, and MILHB0682-18
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), nonfederal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Per 2 CFR 200.403(9), costs must be adequately documented.
Condition - The City duplicated costs charged to certain grants.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Refer to context below
Context - In conjunction with the year-end close process, the City manually reviews invoices received subsequent to year end and identifies amounts to be accrued. These amounts are accrued via manual journal entries posted to period 13. As this is a period 13 entry, the amounts automatically reverse in the new year. During this process, the City duplicated costs to be accrued in the amount of $12,300 under ALN 14.218 (CDBG), $327,709 under ALN 14.241 (HOPWA), and $235,911 under ALN 14.905 (Lead). Despite being accrued, the City did not request reimbursement for these costs, as reimbursement is only requested after expenses are paid. Upon identification of the error, the City reduced the amounts reported on the schedule of expenditures of federal awards (SEFA) by the amounts noted above.
Cause and Effect - The City's control regarding the year-end close process did not identify that certain costs accrued were duplicated. As a result, the initial SEFA provided to the auditors was overstated by these costs. The City excluded the duplicate costs from the final
SEFA.
Recommendation - We recommend the City review its processes and controls to ensure that the preparation and review of journal entries to accrue for costs include a review for duplicate costs.
Views of Responsible Officials and Corrective Action Plan - The City will review its journal entry controls and processes to help ensure journal entries are posted accurately and implement a review for duplicate costs.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.905, United States Department of Housing and Urban Development, Lead Hazard Reduction Demonstration Grant Program
Federal Award Identification Number and Year - MILHD0487-22, MILNG00007-19, MILHB0682-18, program years 2022, 2019, and 2018
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Additionally, per 2 CFR 200.303(b), the nonfederal entity must comply with the U.S. Constitution, federal statutes, regulations, and the terms and conditions of the federal award.
Condition - Certain controls in place did not operate effectively specific to eligibility, earmarking, and reporting compliance requirements.
Certain controls in place were not effective either because of design flaws or due to the lack of fully implemented controls. Our testing revealed that control design flaws existed and certain controls did not operate effectively during the fiscal year.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Controls must be designed effectively in order to be effective. The controls in place for eligibility and earmarking were not designed effectively. For the year ended June 30, 2023, the controls were neither designed to ensure supervisory review and approval of applicants' eligibility nor designed to ensure at least 90 percent of the total number of owner-occupied units assisted have a child occupant under six years of age.
Additionally, controls did not operate effectively to ensure that performance reports submitted agreed to underlying records and/or supporting documentation. For one of the three reports selected for testing, the City overstated the number of units that received evaluations based on the underlying support. The report indicated 19 units received evaluations, while the underlying support showed 10 units.
Cause and Effect - Without adequate controls in place over eligibility determinations and earmarking, ineligible participants could receive program benefits or the City could exceed the 10 percent allowance to provide support for applicants who do not have a child under the age of six, resulting in disallowed costs. Inadequate controls in place over reporting could result in noncompliance with the terms and conditions of the award and could lead to inappropriate decision-making.
Recommendation - We recommend the City maintain on file all terms and conditions outlined by the funding agency. Additionally, we recommend the City review the controls in place for the Lead Hazard Reduction Demonstration Grant Program to ensure that controls are designed effectively and implemented to address the risks of noncompliance identified by the City.
Views of Responsible Officials and Planned Corrective Actions - The City will review its processes and implement additional controls and the required review of eligibility approval is in place and all supporting documentation is stored and maintained.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.905, United States Department of Housing and Urban Development, Lead Hazard Reduction Demonstration Grant Program
Federal Award Identification Number and Year - MILHD0487-22, MILNG00007-19, MILHB0682-18, program years 2022, 2019, and 2018
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Additionally, per 2 CFR 200.303(b), the nonfederal entity must comply with the U.S. Constitution, federal statutes, regulations, and the terms and conditions of the federal award.
Condition - Certain controls in place did not operate effectively specific to eligibility, earmarking, and reporting compliance requirements.
Certain controls in place were not effective either because of design flaws or due to the lack of fully implemented controls. Our testing revealed that control design flaws existed and certain controls did not operate effectively during the fiscal year.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Controls must be designed effectively in order to be effective. The controls in place for eligibility and earmarking were not designed effectively. For the year ended June 30, 2023, the controls were neither designed to ensure supervisory review and approval of applicants' eligibility nor designed to ensure at least 90 percent of the total number of owner-occupied units assisted have a child occupant under six years of age.
Additionally, controls did not operate effectively to ensure that performance reports submitted agreed to underlying records and/or supporting documentation. For one of the three reports selected for testing, the City overstated the number of units that received evaluations based on the underlying support. The report indicated 19 units received evaluations, while the underlying support showed 10 units.
Cause and Effect - Without adequate controls in place over eligibility determinations and earmarking, ineligible participants could receive program benefits or the City could exceed the 10 percent allowance to provide support for applicants who do not have a child under the age of six, resulting in disallowed costs. Inadequate controls in place over reporting could result in noncompliance with the terms and conditions of the award and could lead to inappropriate decision-making.
Recommendation - We recommend the City maintain on file all terms and conditions outlined by the funding agency. Additionally, we recommend the City review the controls in place for the Lead Hazard Reduction Demonstration Grant Program to ensure that controls are designed effectively and implemented to address the risks of noncompliance identified by the City.
Views of Responsible Officials and Planned Corrective Actions - The City will review its processes and implement additional controls and the required review of eligibility approval is in place and all supporting documentation is stored and maintained.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.905, United States Department of Housing and Urban Development, Lead Hazard Reduction Demonstration Grant Program
Federal Award Identification Number and Year - MILHD0487-22, MILNG00007-19, MILHB0682-18, program years 2022, 2019, and 2018
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Additionally, per 2 CFR 200.303(b), the nonfederal entity must comply with the U.S. Constitution, federal statutes, regulations, and the terms and conditions of the federal award.
Condition - Certain controls in place did not operate effectively specific to eligibility, earmarking, and reporting compliance requirements.
Certain controls in place were not effective either because of design flaws or due to the lack of fully implemented controls. Our testing revealed that control design flaws existed and certain controls did not operate effectively during the fiscal year.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Controls must be designed effectively in order to be effective. The controls in place for eligibility and earmarking were not designed effectively. For the year ended June 30, 2023, the controls were neither designed to ensure supervisory review and approval of applicants' eligibility nor designed to ensure at least 90 percent of the total number of owner-occupied units assisted have a child occupant under six years of age.
Additionally, controls did not operate effectively to ensure that performance reports submitted agreed to underlying records and/or supporting documentation. For one of the three reports selected for testing, the City overstated the number of units that received evaluations based on the underlying support. The report indicated 19 units received evaluations, while the underlying support showed 10 units.
Cause and Effect - Without adequate controls in place over eligibility determinations and earmarking, ineligible participants could receive program benefits or the City could exceed the 10 percent allowance to provide support for applicants who do not have a child under the age of six, resulting in disallowed costs. Inadequate controls in place over reporting could result in noncompliance with the terms and conditions of the award and could lead to inappropriate decision-making.
Recommendation - We recommend the City maintain on file all terms and conditions outlined by the funding agency. Additionally, we recommend the City review the controls in place for the Lead Hazard Reduction Demonstration Grant Program to ensure that controls are designed effectively and implemented to address the risks of noncompliance identified by the City.
Views of Responsible Officials and Planned Corrective Actions - The City will review its processes and implement additional controls and the required review of eligibility approval is in place and all supporting documentation is stored and maintained.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.218, Department of Housing and Urban Development, CDBG Entitlement Grants Cluster - Community Development Block Grants Cluster
Federal Award Identification Number and Year - B-22-MC-26-0006, B-21-MC-26-0006, B- 20-MW-26-006
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes, 2022-014
Criteria - The Federal Funding Accountability and Transparency Act (FFATA), as amended by 6202 of Public La 110-252, requires a prime grant awardee to report its subgrants using the FFATA Subaward reporting System (FSRS) tool. The prime recipient will have until the
end of the month plus one additional month after an award or subaward is obligated to fulfill the reporting requirement.
Condition - During reporting testing, we noted that the City did not file one FFATA report, and there were five untimely submissions.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - The City obligated several subawards throughout the year ended June 30, 2023, and the reports were due at end of the month plus one additional month after the award or subaward was obligated.
The following table summarizes the transactions examined and the noncompliance identified: See the finding 2023-012 in Section III of the Schedule of Findings and Questioned Costs for chart/table
Cause and Effect - The Citys processes did not properly identify the FFATA filing requirements resulting in a lack of filing and delay in filing reports.
Recommendation - We recommend the City implement adequate controls to ensure compliance with FFATA reporting requirements.
Views of Responsible Officials and Corrective Action Plan - The City will review its current FFATA processes and implement additional controls to ensure timely and accurate filings and compliance with reporting requirements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.218, Department of Housing and Urban Development, CDBG Entitlement Grants Cluster - Community Development Block Grants Cluster
Federal Award Identification Number and Year - B-22-MC-26-0006, B-21-MC-26-0006, B- 20-MW-26-006
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes, 2022-014
Criteria - The Federal Funding Accountability and Transparency Act (FFATA), as amended by 6202 of Public La 110-252, requires a prime grant awardee to report its subgrants using the FFATA Subaward reporting System (FSRS) tool. The prime recipient will have until the
end of the month plus one additional month after an award or subaward is obligated to fulfill the reporting requirement.
Condition - During reporting testing, we noted that the City did not file one FFATA report, and there were five untimely submissions.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - The City obligated several subawards throughout the year ended June 30, 2023, and the reports were due at end of the month plus one additional month after the award or subaward was obligated.
The following table summarizes the transactions examined and the noncompliance identified: See the finding 2023-012 in Section III of the Schedule of Findings and Questioned Costs for chart/table
Cause and Effect - The Citys processes did not properly identify the FFATA filing requirements resulting in a lack of filing and delay in filing reports.
Recommendation - We recommend the City implement adequate controls to ensure compliance with FFATA reporting requirements.
Views of Responsible Officials and Corrective Action Plan - The City will review its current FFATA processes and implement additional controls to ensure timely and accurate filings and compliance with reporting requirements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.218, Department of Housing and Urban Development, CDBG Entitlement Grants Cluster - Community Development Block Grants Cluster
Federal Award Identification Number and Year - B-22-MC-26-0006, B-21-MC-26-0006, B- 20-MW-26-006
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes, 2022-014
Criteria - The Federal Funding Accountability and Transparency Act (FFATA), as amended by 6202 of Public La 110-252, requires a prime grant awardee to report its subgrants using the FFATA Subaward reporting System (FSRS) tool. The prime recipient will have until the
end of the month plus one additional month after an award or subaward is obligated to fulfill the reporting requirement.
Condition - During reporting testing, we noted that the City did not file one FFATA report, and there were five untimely submissions.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - The City obligated several subawards throughout the year ended June 30, 2023, and the reports were due at end of the month plus one additional month after the award or subaward was obligated.
The following table summarizes the transactions examined and the noncompliance identified: See the finding 2023-012 in Section III of the Schedule of Findings and Questioned Costs for chart/table
Cause and Effect - The Citys processes did not properly identify the FFATA filing requirements resulting in a lack of filing and delay in filing reports.
Recommendation - We recommend the City implement adequate controls to ensure compliance with FFATA reporting requirements.
Views of Responsible Officials and Corrective Action Plan - The City will review its current FFATA processes and implement additional controls to ensure timely and accurate filings and compliance with reporting requirements.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC)
Federal Award Identification Number and Year - 213MI013W5003, 212MI003W1003, program years 2022 and 2023
Pass-through Entity - Michigan Department of Health and Human Services
Finding Type - Material weakness
Repeat Finding - Yes
2022-006
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The City did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - The City entered into an agreement with a contractor to perform eligibility intake for WIC applicants. While the City arranges for the contractor to perform the intake function, the City is fully responsible for the federal compliance for the eligibility determination process. Testing revealed that the contractor's staff performed both initial and secondary reviews during the intake process. Procedures further revealed that the City did not have any control in place to exercise its oversight responsibility of the grant and relied solely on the contractor's eligibility determinations through May 2023.
Cause and Effect - In the current year, the City contracted with a contractor to perform the eligibility intake function and other programmatic decisions for WIC. However, the City did not implement controls to ensure eligibility conclusions reached by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor's procedures to determine participant eligibility, ineligible participants could receive program benefits.
Recommendation - We recommend the City develop oversight procedures to review the work completed by contractors, which pertains to compliance requirements and programmatic decisions, in this case, participant eligibility determination.
Views of Responsible Officials and Planned Corrective Actions - The City has implemented controls to ensure that the Health Department provides oversight over the contractors. A new contract was in place in May, and the Health Department hired a WIC
program director to monitor participant eligibility compliance and ensure policies and procedures are maintained and followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC)
Federal Award Identification Number and Year - 213MI013W5003, 212MI003W1003, program years 2022 and 2023
Pass-through Entity - Michigan Department of Health and Human Services
Finding Type - Material weakness
Repeat Finding - Yes
2022-006
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The City did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - The City entered into an agreement with a contractor to perform eligibility intake for WIC applicants. While the City arranges for the contractor to perform the intake function, the City is fully responsible for the federal compliance for the eligibility determination process. Testing revealed that the contractor's staff performed both initial and secondary reviews during the intake process. Procedures further revealed that the City did not have any control in place to exercise its oversight responsibility of the grant and relied solely on the contractor's eligibility determinations through May 2023.
Cause and Effect - In the current year, the City contracted with a contractor to perform the eligibility intake function and other programmatic decisions for WIC. However, the City did not implement controls to ensure eligibility conclusions reached by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor's procedures to determine participant eligibility, ineligible participants could receive program benefits.
Recommendation - We recommend the City develop oversight procedures to review the work completed by contractors, which pertains to compliance requirements and programmatic decisions, in this case, participant eligibility determination.
Views of Responsible Officials and Planned Corrective Actions - The City has implemented controls to ensure that the Health Department provides oversight over the contractors. A new contract was in place in May, and the Health Department hired a WIC
program director to monitor participant eligibility compliance and ensure policies and procedures are maintained and followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC)
Federal Award Identification Number and Year - 213MI013W5003, 212MI003W1003, program years 2022 and 2023
Pass-through Entity - Michigan Department of Health and Human Services
Finding Type - Material weakness
Repeat Finding - Yes
2022-006
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The City did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - The City entered into an agreement with a contractor to perform eligibility intake for WIC applicants. While the City arranges for the contractor to perform the intake function, the City is fully responsible for the federal compliance for the eligibility determination process. Testing revealed that the contractor's staff performed both initial and secondary reviews during the intake process. Procedures further revealed that the City did not have any control in place to exercise its oversight responsibility of the grant and relied solely on the contractor's eligibility determinations through May 2023.
Cause and Effect - In the current year, the City contracted with a contractor to perform the eligibility intake function and other programmatic decisions for WIC. However, the City did not implement controls to ensure eligibility conclusions reached by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor's procedures to determine participant eligibility, ineligible participants could receive program benefits.
Recommendation - We recommend the City develop oversight procedures to review the work completed by contractors, which pertains to compliance requirements and programmatic decisions, in this case, participant eligibility determination.
Views of Responsible Officials and Planned Corrective Actions - The City has implemented controls to ensure that the Health Department provides oversight over the contractors. A new contract was in place in May, and the Health Department hired a WIC
program director to monitor participant eligibility compliance and ensure policies and procedures are maintained and followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC)
Federal Award Identification Number and Year - 213MI013W5003, 212MI003W1003, program years 2022 and 2023
Pass-through Entity - Michigan Department of Health and Human Services
Finding Type - Material weakness
Repeat Finding - Yes
2022-006
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The City did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - The City entered into an agreement with a contractor to perform eligibility intake for WIC applicants. While the City arranges for the contractor to perform the intake function, the City is fully responsible for the federal compliance for the eligibility determination process. Testing revealed that the contractor's staff performed both initial and secondary reviews during the intake process. Procedures further revealed that the City did not have any control in place to exercise its oversight responsibility of the grant and relied solely on the contractor's eligibility determinations through May 2023.
Cause and Effect - In the current year, the City contracted with a contractor to perform the eligibility intake function and other programmatic decisions for WIC. However, the City did not implement controls to ensure eligibility conclusions reached by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor's procedures to determine participant eligibility, ineligible participants could receive program benefits.
Recommendation - We recommend the City develop oversight procedures to review the work completed by contractors, which pertains to compliance requirements and programmatic decisions, in this case, participant eligibility determination.
Views of Responsible Officials and Planned Corrective Actions - The City has implemented controls to ensure that the Health Department provides oversight over the contractors. A new contract was in place in May, and the Health Department hired a WIC
program director to monitor participant eligibility compliance and ensure policies and procedures are maintained and followed.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC)
Federal Award Identification Number and Year - 213MI013W5003, 212MI003W1003, program years 2022 and 2023
Pass-through Entity - Michigan Department of Health and Human Services
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a nonfederal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end of the period of
performance, as specified in the terms and conditions of the federal award. However, as outlined within the grant award from the Michigan Department of Health and Human Services and more restrictive than 2 CFR 200.344(b), the City must liquidate within 60 days after the State's fiscal year end any unpaid year-end commitments and obligations. Any obligation remaining unliquidated after 60 days from the end of the period shall revert to the State for disposition in accordance with applicable state and/or federal requirements, except as specifically authorized in writing by the department.
Condition - The City did not have adequate controls in place to ensure obligations were liquidated (paid) within the required 60 days.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Refer to context below.
Context - Testing revealed 3 invoices out of 25 were liquidated after the required 60 days for the performance period ended September 30, 2022. Based on email communication received by the City from the Michigan Department of Health and Human Services, the department granted the City retroactive approval to allow for the expenses despite being liquidated after the 60-day period. As a result, no questioned costs are reported.
Cause and Effect - Failure to comply with the terms and conditions of the grant agreement, including the liquidation provisions, may result in disallowed costs and the need to repay the funder for such costs.
Recommendation - We recommend the City ensure controls are in place to comply with liquidation requirements outlined in the award agreements and/or Uniform Guidance issued by 0MB (whichever is more restrictive).
Views of Responsible Officials and Planned Corrective Actions - The OCFO will work with the Health Department to implement additional controls to ensure all subrecipients and contractors submit invoices timely and that they are reviewed, approved, and processed for
payment prior to the 60-day liquidation requirement period.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC)
Federal Award Identification Number and Year - 213MI013W5003, 212MI003W1003, program years 2022 and 2023
Pass-through Entity - Michigan Department of Health and Human Services
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a nonfederal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end of the period of
performance, as specified in the terms and conditions of the federal award. However, as outlined within the grant award from the Michigan Department of Health and Human Services and more restrictive than 2 CFR 200.344(b), the City must liquidate within 60 days after the State's fiscal year end any unpaid year-end commitments and obligations. Any obligation remaining unliquidated after 60 days from the end of the period shall revert to the State for disposition in accordance with applicable state and/or federal requirements, except as specifically authorized in writing by the department.
Condition - The City did not have adequate controls in place to ensure obligations were liquidated (paid) within the required 60 days.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Refer to context below.
Context - Testing revealed 3 invoices out of 25 were liquidated after the required 60 days for the performance period ended September 30, 2022. Based on email communication received by the City from the Michigan Department of Health and Human Services, the department granted the City retroactive approval to allow for the expenses despite being liquidated after the 60-day period. As a result, no questioned costs are reported.
Cause and Effect - Failure to comply with the terms and conditions of the grant agreement, including the liquidation provisions, may result in disallowed costs and the need to repay the funder for such costs.
Recommendation - We recommend the City ensure controls are in place to comply with liquidation requirements outlined in the award agreements and/or Uniform Guidance issued by 0MB (whichever is more restrictive).
Views of Responsible Officials and Planned Corrective Actions - The OCFO will work with the Health Department to implement additional controls to ensure all subrecipients and contractors submit invoices timely and that they are reviewed, approved, and processed for
payment prior to the 60-day liquidation requirement period.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC)
Federal Award Identification Number and Year - 213MI013W5003, 212MI003W1003, program years 2022 and 2023
Pass-through Entity - Michigan Department of Health and Human Services
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a nonfederal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end of the period of
performance, as specified in the terms and conditions of the federal award. However, as outlined within the grant award from the Michigan Department of Health and Human Services and more restrictive than 2 CFR 200.344(b), the City must liquidate within 60 days after the State's fiscal year end any unpaid year-end commitments and obligations. Any obligation remaining unliquidated after 60 days from the end of the period shall revert to the State for disposition in accordance with applicable state and/or federal requirements, except as specifically authorized in writing by the department.
Condition - The City did not have adequate controls in place to ensure obligations were liquidated (paid) within the required 60 days.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Refer to context below.
Context - Testing revealed 3 invoices out of 25 were liquidated after the required 60 days for the performance period ended September 30, 2022. Based on email communication received by the City from the Michigan Department of Health and Human Services, the department granted the City retroactive approval to allow for the expenses despite being liquidated after the 60-day period. As a result, no questioned costs are reported.
Cause and Effect - Failure to comply with the terms and conditions of the grant agreement, including the liquidation provisions, may result in disallowed costs and the need to repay the funder for such costs.
Recommendation - We recommend the City ensure controls are in place to comply with liquidation requirements outlined in the award agreements and/or Uniform Guidance issued by 0MB (whichever is more restrictive).
Views of Responsible Officials and Planned Corrective Actions - The OCFO will work with the Health Department to implement additional controls to ensure all subrecipients and contractors submit invoices timely and that they are reviewed, approved, and processed for
payment prior to the 60-day liquidation requirement period.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC)
Federal Award Identification Number and Year - 213MI013W5003, 212MI003W1003, program years 2022 and 2023
Pass-through Entity - Michigan Department of Health and Human Services
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a nonfederal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end of the period of
performance, as specified in the terms and conditions of the federal award. However, as outlined within the grant award from the Michigan Department of Health and Human Services and more restrictive than 2 CFR 200.344(b), the City must liquidate within 60 days after the State's fiscal year end any unpaid year-end commitments and obligations. Any obligation remaining unliquidated after 60 days from the end of the period shall revert to the State for disposition in accordance with applicable state and/or federal requirements, except as specifically authorized in writing by the department.
Condition - The City did not have adequate controls in place to ensure obligations were liquidated (paid) within the required 60 days.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Refer to context below.
Context - Testing revealed 3 invoices out of 25 were liquidated after the required 60 days for the performance period ended September 30, 2022. Based on email communication received by the City from the Michigan Department of Health and Human Services, the department granted the City retroactive approval to allow for the expenses despite being liquidated after the 60-day period. As a result, no questioned costs are reported.
Cause and Effect - Failure to comply with the terms and conditions of the grant agreement, including the liquidation provisions, may result in disallowed costs and the need to repay the funder for such costs.
Recommendation - We recommend the City ensure controls are in place to comply with liquidation requirements outlined in the award agreements and/or Uniform Guidance issued by 0MB (whichever is more restrictive).
Views of Responsible Officials and Planned Corrective Actions - The OCFO will work with the Health Department to implement additional controls to ensure all subrecipients and contractors submit invoices timely and that they are reviewed, approved, and processed for
payment prior to the 60-day liquidation requirement period.
Assistance Listing Number, Federal Agency, and Program Name - ALN 20.507, Department of Transportation, Federal Transit Cluster - Federal Transit Formula Grants
Federal Award Identification Number and Year - Ml-2022-026-00, program year 2022
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The City did not have adequate controls in place to ensure payroll costs charged to the program were accurate in relation to underlying payroll records.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Refer to context below.
Context - Testing revealed approximately $141,000 in credit adjustments was incorrectly excluded from a $14,419,000 adjusting journal entry to increase payroll costs charged to the program during the fiscal period under audit.
The pool of gross payroll costs identified by the City for allocation to the grant under the final adjusting journal entry, which includes the costs described in the preceding paragraph, totaled approximately $20,932,000. However, the City only allocated approximately $18,620,000 of these gross payroll costs to the grant to align with the budgeted use of the funds for the fiscal period. The City in essence had $20,791,000 of eligible expenses, after accounting for the approximately $141,000 of credit adjustments, to expend the remaining $14,419,000 award amount. The City did not specifically identify which transactions within the payroll cost population were not ultimately allocated to the program. After identifying approximately $4,201,000 of payroll already charged to the program through the City's usual biweekly payroll process, the City's internal control procedures did not include a verification process to ensure that the payroll records used to develop the $14,419,000 adjusting entry to true up payroll costs agreed to underlying payroll records. Given that the City did not need to allocate the entire $20,932,000, the $141,000 overstatement is not considered questioned costs, as there was approximately $2,300,000 of eligible costs not allocated.
Cause and Effect - The lack of controls surrounding the payroll adjustment resulted in payroll costs that were overstated in relation to the underlying payroll register. The lack of controls could result in disallowed costs.
Recommendation - We recommend the City ensure controls are in place to verify the accuracy and completeness of amounts charged to the grant against supporting documentation and underlying records.
Views of Responsible Officials and Planned Corrective Actions - The City will ensure the required controls are in place to help ensure accurate payroll costs are charged to the program and completeness of the supporting documentation.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 21 .027, Department the of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Federal Award Identification Number and Year- N/A
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period from October 1, 2022 through December 31, 2022 (Quarter 4).
Questioned Costs - N/A
Identification of How Questioned Costs Were Computed - N/A
Context - In our sample of two performance reports selected for testing, we noted one instance where certain information reported did not agree to the general ledger and underlying records.
Cause and Effect - The City's controls were not adequate to ensure that underlying data for reports was consistently accumulated. The payroll data for the report submitted for the period from July 1, 2022 through September 30, 2022 (Quarter 3) was accumulated from the payroll system and appropriately reflected the payroll costs. The general ledger at the time did not yet fully reflect transactions due to timing. For Quarter 4, the City accumulated the payroll costs based on the general ledger, and, as a result, certain costs reported in Quarter 3 were reported again in the Quarter 4. The Quarter 4 report was overstated by $21,670.
Recommendation - We recommend the City implement a process to ensure that reports are completed based on a consistent methodology and a detail review be performed to ensure accuracy.
Views of Responsible Officials and Planned Corrective Actions - The City will implement additional controls to ensure that the quarterly Treasury reports align with the expenses stated on the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID-19 HOPWA
Federal Award Identification Number and Year - MIH20-FHW001, MIH20-F001, MIH21- F001, MIH22-F001
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2022-007
Criteria - Per 24 CFR 574.310, except for persons in short-term supportive housing, each person receiving rental assistance under the HOPWA program must pay as rent the higher of (1) 30 percent of the family's monthly adjusted gross income; (2) 10 percent of the family's monthly gross income; or (3) the portion of the payments that is designated if the family is receiving payments for welfare assistance from a public agency and a part of the payments, adjusted in accordance with the family's actual housing costs, that is specifically designated by the agency to meet the family's housing costs.
Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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 the 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).
Condition - In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation and distribution of benefits were identified.
Questioned Costs - $3,022
Identification of How Questioned Costs Were Computed - Questioned costs reflect the gross overpayments. See context below for instances of benefits being overpaid.
Context - During eligibility testing of a sample of 60, we noted the following:
• A lack of effective supervisory review of the annual certification process and calculation of benefits resulted in one instance of benefits being overpaid by $176 and four instances of benefits being underpaid by $221 based on income and family size.
• A lack of effective supervisory review over the distribution of benefits throughout the benefit agreement period resulted in two instances of an overpayment of benefits by $2,846 and one instances of an underpayment of benefits by $10.
Cause and Effect - The lack of adequate controls in the form of detailed reviews over the calculation and payment of rental assistance, based on the requirements of 24 CFR 574.310, resulted in both overpayments and underpayments of rental assistance to beneficiaries.
Recommendation - We recommend the City review its procedures and controls specific to the calculation and distribution of rental assistance and make modifications as necessary to ensure that inputs of the calculation are reviewed for completeness and accuracy and that the payments are consistent with the calculation prior to finalizing the benefit agreements and communicating the same to the participant.
Views of Responsible Officials and Planned Corrective Actions - City of Detroit HOPWA program has a dedicated quality coordinator position. The coordinator will continue to work closely with the HOPWA program team and conduct regular file audits. The HOPWA program team has also implemented additional steps, including the use of eligibility templates to help ensure accurate rental assistance calculations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID-19 HOPWA
Federal Award Identification Number and Year - MIH20-FHW001, MIH20-F001, MIH21- F001, MIH22-F001
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2022-007
Criteria - Per 24 CFR 574.310, except for persons in short-term supportive housing, each person receiving rental assistance under the HOPWA program must pay as rent the higher of (1) 30 percent of the family's monthly adjusted gross income; (2) 10 percent of the family's monthly gross income; or (3) the portion of the payments that is designated if the family is receiving payments for welfare assistance from a public agency and a part of the payments, adjusted in accordance with the family's actual housing costs, that is specifically designated by the agency to meet the family's housing costs.
Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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 the 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).
Condition - In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation and distribution of benefits were identified.
Questioned Costs - $3,022
Identification of How Questioned Costs Were Computed - Questioned costs reflect the gross overpayments. See context below for instances of benefits being overpaid.
Context - During eligibility testing of a sample of 60, we noted the following:
• A lack of effective supervisory review of the annual certification process and calculation of benefits resulted in one instance of benefits being overpaid by $176 and four instances of benefits being underpaid by $221 based on income and family size.
• A lack of effective supervisory review over the distribution of benefits throughout the benefit agreement period resulted in two instances of an overpayment of benefits by $2,846 and one instances of an underpayment of benefits by $10.
Cause and Effect - The lack of adequate controls in the form of detailed reviews over the calculation and payment of rental assistance, based on the requirements of 24 CFR 574.310, resulted in both overpayments and underpayments of rental assistance to beneficiaries.
Recommendation - We recommend the City review its procedures and controls specific to the calculation and distribution of rental assistance and make modifications as necessary to ensure that inputs of the calculation are reviewed for completeness and accuracy and that the payments are consistent with the calculation prior to finalizing the benefit agreements and communicating the same to the participant.
Views of Responsible Officials and Planned Corrective Actions - City of Detroit HOPWA program has a dedicated quality coordinator position. The coordinator will continue to work closely with the HOPWA program team and conduct regular file audits. The HOPWA program team has also implemented additional steps, including the use of eligibility templates to help ensure accurate rental assistance calculations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID-19 HOPWA
Federal Award Identification Number and Year - MIH20-FHW001, MIH20-F001, MIH21- F001, MIH22-F001
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2022-007
Criteria - Per 24 CFR 574.310, except for persons in short-term supportive housing, each person receiving rental assistance under the HOPWA program must pay as rent the higher of (1) 30 percent of the family's monthly adjusted gross income; (2) 10 percent of the family's monthly gross income; or (3) the portion of the payments that is designated if the family is receiving payments for welfare assistance from a public agency and a part of the payments, adjusted in accordance with the family's actual housing costs, that is specifically designated by the agency to meet the family's housing costs.
Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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 the 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).
Condition - In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation and distribution of benefits were identified.
Questioned Costs - $3,022
Identification of How Questioned Costs Were Computed - Questioned costs reflect the gross overpayments. See context below for instances of benefits being overpaid.
Context - During eligibility testing of a sample of 60, we noted the following:
• A lack of effective supervisory review of the annual certification process and calculation of benefits resulted in one instance of benefits being overpaid by $176 and four instances of benefits being underpaid by $221 based on income and family size.
• A lack of effective supervisory review over the distribution of benefits throughout the benefit agreement period resulted in two instances of an overpayment of benefits by $2,846 and one instances of an underpayment of benefits by $10.
Cause and Effect - The lack of adequate controls in the form of detailed reviews over the calculation and payment of rental assistance, based on the requirements of 24 CFR 574.310, resulted in both overpayments and underpayments of rental assistance to beneficiaries.
Recommendation - We recommend the City review its procedures and controls specific to the calculation and distribution of rental assistance and make modifications as necessary to ensure that inputs of the calculation are reviewed for completeness and accuracy and that the payments are consistent with the calculation prior to finalizing the benefit agreements and communicating the same to the participant.
Views of Responsible Officials and Planned Corrective Actions - City of Detroit HOPWA program has a dedicated quality coordinator position. The coordinator will continue to work closely with the HOPWA program team and conduct regular file audits. The HOPWA program team has also implemented additional steps, including the use of eligibility templates to help ensure accurate rental assistance calculations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID-19 HOPWA
Federal Award Identification Number and Year - MIH20-FHW001, MIH20-F001, MIH21- F001, MIH22-F001
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - Yes
2022-007
Criteria - Per 24 CFR 574.310, except for persons in short-term supportive housing, each person receiving rental assistance under the HOPWA program must pay as rent the higher of (1) 30 percent of the family's monthly adjusted gross income; (2) 10 percent of the family's monthly gross income; or (3) the portion of the payments that is designated if the family is receiving payments for welfare assistance from a public agency and a part of the payments, adjusted in accordance with the family's actual housing costs, that is specifically designated by the agency to meet the family's housing costs.
Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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 the 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).
Condition - In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation and distribution of benefits were identified.
Questioned Costs - $3,022
Identification of How Questioned Costs Were Computed - Questioned costs reflect the gross overpayments. See context below for instances of benefits being overpaid.
Context - During eligibility testing of a sample of 60, we noted the following:
• A lack of effective supervisory review of the annual certification process and calculation of benefits resulted in one instance of benefits being overpaid by $176 and four instances of benefits being underpaid by $221 based on income and family size.
• A lack of effective supervisory review over the distribution of benefits throughout the benefit agreement period resulted in two instances of an overpayment of benefits by $2,846 and one instances of an underpayment of benefits by $10.
Cause and Effect - The lack of adequate controls in the form of detailed reviews over the calculation and payment of rental assistance, based on the requirements of 24 CFR 574.310, resulted in both overpayments and underpayments of rental assistance to beneficiaries.
Recommendation - We recommend the City review its procedures and controls specific to the calculation and distribution of rental assistance and make modifications as necessary to ensure that inputs of the calculation are reviewed for completeness and accuracy and that the payments are consistent with the calculation prior to finalizing the benefit agreements and communicating the same to the participant.
Views of Responsible Officials and Planned Corrective Actions - City of Detroit HOPWA program has a dedicated quality coordinator position. The coordinator will continue to work closely with the HOPWA program team and conduct regular file audits. The HOPWA program team has also implemented additional steps, including the use of eligibility templates to help ensure accurate rental assistance calculations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID-19 HOPWA
Federal Award Identification Number and Year - MIH20-FHW001, MIH20-F001, MIH21- F001, MIH22-F001
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Under 0MB Number 2506-40110-C, on an annual basis, HOPWA formula grantees are required to submit a Consolidated Annual Performance and Evaluation Report (CAPER) demonstrating essential information on grant activities, project sponsors, housing sites, units and households, and beneficiaries. Per 2 CFR 200.302(b), the nonfederal entity must maintain a financial management system that provides records that identify adequately the source and application of funds for federally funded activities.
Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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 the 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).
Condition - The controls in place were not adequate to ensure that amounts reported within the CAPER were accurate and complete in relation to activity reported in the general ledger and underlying records of the City.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Management has a process in place to compile beneficiary headcounts, rental assistance, and other costs for reporting within the CAPER; however, management did not maintain the underlying records to support the amounts and expenditures reported in the
CAPER submitted for program year ended June 30, 2023. Where we were able to perform procedures to reconcile to the beneficiary headcount, we identified approximately $3.9 million of expenditures reported within the CAPER was understated by approximately $300,000 in relation to the amounts reported in the general ledger.
Cause and Effect - Not maintaining the underlying records and supporting documentation may lead to inaccurate information being reported to the funder and could perhaps inappropriately influence subsequent decisions.
Recommendation - We recommend the City implement a system of internal controls to ensure that records used in reporting information to the funding agency are retained in support of the amounts and that supervisory review over those inputs are in place. Additionally, we recommend the City reconcile the books and records timely to ensure accurate and complete reporting of program activity.
Views of Responsible Officials and Planned Corrective Actions - The City will review its current process and implement additional reporting controls, including verification of expenditures, retention of supporting documentation, and a timely final reconciliation of the CAPER to the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID-19 HOPWA
Federal Award Identification Number and Year - MIH20-FHW001, MIH20-F001, MIH21- F001, MIH22-F001
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Under 0MB Number 2506-40110-C, on an annual basis, HOPWA formula grantees are required to submit a Consolidated Annual Performance and Evaluation Report (CAPER) demonstrating essential information on grant activities, project sponsors, housing sites, units and households, and beneficiaries. Per 2 CFR 200.302(b), the nonfederal entity must maintain a financial management system that provides records that identify adequately the source and application of funds for federally funded activities.
Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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 the 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).
Condition - The controls in place were not adequate to ensure that amounts reported within the CAPER were accurate and complete in relation to activity reported in the general ledger and underlying records of the City.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Management has a process in place to compile beneficiary headcounts, rental assistance, and other costs for reporting within the CAPER; however, management did not maintain the underlying records to support the amounts and expenditures reported in the
CAPER submitted for program year ended June 30, 2023. Where we were able to perform procedures to reconcile to the beneficiary headcount, we identified approximately $3.9 million of expenditures reported within the CAPER was understated by approximately $300,000 in relation to the amounts reported in the general ledger.
Cause and Effect - Not maintaining the underlying records and supporting documentation may lead to inaccurate information being reported to the funder and could perhaps inappropriately influence subsequent decisions.
Recommendation - We recommend the City implement a system of internal controls to ensure that records used in reporting information to the funding agency are retained in support of the amounts and that supervisory review over those inputs are in place. Additionally, we recommend the City reconcile the books and records timely to ensure accurate and complete reporting of program activity.
Views of Responsible Officials and Planned Corrective Actions - The City will review its current process and implement additional reporting controls, including verification of expenditures, retention of supporting documentation, and a timely final reconciliation of the CAPER to the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID-19 HOPWA
Federal Award Identification Number and Year - MIH20-FHW001, MIH20-F001, MIH21- F001, MIH22-F001
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Under 0MB Number 2506-40110-C, on an annual basis, HOPWA formula grantees are required to submit a Consolidated Annual Performance and Evaluation Report (CAPER) demonstrating essential information on grant activities, project sponsors, housing sites, units and households, and beneficiaries. Per 2 CFR 200.302(b), the nonfederal entity must maintain a financial management system that provides records that identify adequately the source and application of funds for federally funded activities.
Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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 the 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).
Condition - The controls in place were not adequate to ensure that amounts reported within the CAPER were accurate and complete in relation to activity reported in the general ledger and underlying records of the City.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Management has a process in place to compile beneficiary headcounts, rental assistance, and other costs for reporting within the CAPER; however, management did not maintain the underlying records to support the amounts and expenditures reported in the
CAPER submitted for program year ended June 30, 2023. Where we were able to perform procedures to reconcile to the beneficiary headcount, we identified approximately $3.9 million of expenditures reported within the CAPER was understated by approximately $300,000 in relation to the amounts reported in the general ledger.
Cause and Effect - Not maintaining the underlying records and supporting documentation may lead to inaccurate information being reported to the funder and could perhaps inappropriately influence subsequent decisions.
Recommendation - We recommend the City implement a system of internal controls to ensure that records used in reporting information to the funding agency are retained in support of the amounts and that supervisory review over those inputs are in place. Additionally, we recommend the City reconcile the books and records timely to ensure accurate and complete reporting of program activity.
Views of Responsible Officials and Planned Corrective Actions - The City will review its current process and implement additional reporting controls, including verification of expenditures, retention of supporting documentation, and a timely final reconciliation of the CAPER to the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons With AIDS (HOPWA) and COVID-19 HOPWA
Federal Award Identification Number and Year - MIH20-FHW001, MIH20-F001, MIH21- F001, MIH22-F001
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Under 0MB Number 2506-40110-C, on an annual basis, HOPWA formula grantees are required to submit a Consolidated Annual Performance and Evaluation Report (CAPER) demonstrating essential information on grant activities, project sponsors, housing sites, units and households, and beneficiaries. Per 2 CFR 200.302(b), the nonfederal entity must maintain a financial management system that provides records that identify adequately the source and application of funds for federally funded activities.
Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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 the 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).
Condition - The controls in place were not adequate to ensure that amounts reported within the CAPER were accurate and complete in relation to activity reported in the general ledger and underlying records of the City.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Management has a process in place to compile beneficiary headcounts, rental assistance, and other costs for reporting within the CAPER; however, management did not maintain the underlying records to support the amounts and expenditures reported in the
CAPER submitted for program year ended June 30, 2023. Where we were able to perform procedures to reconcile to the beneficiary headcount, we identified approximately $3.9 million of expenditures reported within the CAPER was understated by approximately $300,000 in relation to the amounts reported in the general ledger.
Cause and Effect - Not maintaining the underlying records and supporting documentation may lead to inaccurate information being reported to the funder and could perhaps inappropriately influence subsequent decisions.
Recommendation - We recommend the City implement a system of internal controls to ensure that records used in reporting information to the funding agency are retained in support of the amounts and that supervisory review over those inputs are in place. Additionally, we recommend the City reconcile the books and records timely to ensure accurate and complete reporting of program activity.
Views of Responsible Officials and Planned Corrective Actions - The City will review its current process and implement additional reporting controls, including verification of expenditures, retention of supporting documentation, and a timely final reconciliation of the CAPER to the general ledger.
Assistance Listing Number, Federal Agency, and Program Name - ALN 93.914, Department of Health and Human Services, HIV Emergency Relief Project Grants
Federal Award Identification Number and Year - 6 H89HA00021-31-01, 6 H89hA00021 29- 01
Pass-through Entity - N/A
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - Per 45 CFR 75.303(a), a nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The City did not provide a formal report on monitoring performed for 3 of its subrecipients.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - In the case of 3 out of the City's 14 subrecipients that received funding under the above-mentioned award, the City's communication to the subrecipients related to the results of the monitoring was significantly delayed. Communication was sent approximately one year subsequent to the monitoring procedures. Based on the reports, there were no matters noted requiring a corrective action plan from the subrecipients. The reports also did not reveal any questioned costs.
Cause and Effect - There were no controls in place to ensure monitoring results were communicated timely to subrecipients subsequent to a staff member's departure. The lack of timely communication could result in delayed corrective action and possible disallowance of costs.
Recommendation - We recommend the City review its controls to ensure the entire cycle of monitoring, from the planning phase to the close-out phase, is completed in a timely manner.
Views of Responsible Officials and Planned Corrective Actions - The City will review its subrecipient monitoring policy and implement additional controls to ensure an end-to-end monitoring process is in place that includes timely communication of the reports.
Assistance Listing Number, Federal Agency, and Program Name - ALN 93.914, Department of Health and Human Services, HIV Emergency Relief Project Grants
Federal Award Identification Number and Year - 6 H89HA00021-31-01, 6 H89hA00021 29- 01
Pass-through Entity - N/A
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - Per 45 CFR 75.303(a), a nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Condition - The City did not provide a formal report on monitoring performed for 3 of its subrecipients.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - In the case of 3 out of the City's 14 subrecipients that received funding under the above-mentioned award, the City's communication to the subrecipients related to the results of the monitoring was significantly delayed. Communication was sent approximately one year subsequent to the monitoring procedures. Based on the reports, there were no matters noted requiring a corrective action plan from the subrecipients. The reports also did not reveal any questioned costs.
Cause and Effect - There were no controls in place to ensure monitoring results were communicated timely to subrecipients subsequent to a staff member's departure. The lack of timely communication could result in delayed corrective action and possible disallowance of costs.
Recommendation - We recommend the City review its controls to ensure the entire cycle of monitoring, from the planning phase to the close-out phase, is completed in a timely manner.
Views of Responsible Officials and Planned Corrective Actions - The City will review its subrecipient monitoring policy and implement additional controls to ensure an end-to-end monitoring process is in place that includes timely communication of the reports.
Assistance Listing Number, Federal Agency, and Program Name - 14.218, Department of Housing and Urban Development, CDBG Entitlement Grants Cluster - Community Development Block Grant/Entitlement Grants (CDBG)
14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With Aids (HOPWA)
14.905, Department of Housing and Urban Development, Lead Hazard Reduction Demonstration Grant Program (Lead)
Federal Award Identification Number and Year -
CDBG - B-22-MC-26-0006
HOPWA - MIH22F001
Lead - MILNG0007-19, and MILHB0682-18
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), nonfederal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Per 2 CFR 200.403(9), costs must be adequately documented.
Condition - The City duplicated costs charged to certain grants.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Refer to context below
Context - In conjunction with the year-end close process, the City manually reviews invoices received subsequent to year end and identifies amounts to be accrued. These amounts are accrued via manual journal entries posted to period 13. As this is a period 13 entry, the amounts automatically reverse in the new year. During this process, the City duplicated costs to be accrued in the amount of $12,300 under ALN 14.218 (CDBG), $327,709 under ALN 14.241 (HOPWA), and $235,911 under ALN 14.905 (Lead). Despite being accrued, the City did not request reimbursement for these costs, as reimbursement is only requested after expenses are paid. Upon identification of the error, the City reduced the amounts reported on the schedule of expenditures of federal awards (SEFA) by the amounts noted above.
Cause and Effect - The City's control regarding the year-end close process did not identify that certain costs accrued were duplicated. As a result, the initial SEFA provided to the auditors was overstated by these costs. The City excluded the duplicate costs from the final
SEFA.
Recommendation - We recommend the City review its processes and controls to ensure that the preparation and review of journal entries to accrue for costs include a review for duplicate costs.
Views of Responsible Officials and Corrective Action Plan - The City will review its journal entry controls and processes to help ensure journal entries are posted accurately and implement a review for duplicate costs.
Assistance Listing Number, Federal Agency, and Program Name - 14.218, Department of Housing and Urban Development, CDBG Entitlement Grants Cluster - Community Development Block Grant/Entitlement Grants (CDBG)
14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With Aids (HOPWA)
14.905, Department of Housing and Urban Development, Lead Hazard Reduction Demonstration Grant Program (Lead)
Federal Award Identification Number and Year -
CDBG - B-22-MC-26-0006
HOPWA - MIH22F001
Lead - MILNG0007-19, and MILHB0682-18
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), nonfederal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Per 2 CFR 200.403(9), costs must be adequately documented.
Condition - The City duplicated costs charged to certain grants.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Refer to context below
Context - In conjunction with the year-end close process, the City manually reviews invoices received subsequent to year end and identifies amounts to be accrued. These amounts are accrued via manual journal entries posted to period 13. As this is a period 13 entry, the amounts automatically reverse in the new year. During this process, the City duplicated costs to be accrued in the amount of $12,300 under ALN 14.218 (CDBG), $327,709 under ALN 14.241 (HOPWA), and $235,911 under ALN 14.905 (Lead). Despite being accrued, the City did not request reimbursement for these costs, as reimbursement is only requested after expenses are paid. Upon identification of the error, the City reduced the amounts reported on the schedule of expenditures of federal awards (SEFA) by the amounts noted above.
Cause and Effect - The City's control regarding the year-end close process did not identify that certain costs accrued were duplicated. As a result, the initial SEFA provided to the auditors was overstated by these costs. The City excluded the duplicate costs from the final
SEFA.
Recommendation - We recommend the City review its processes and controls to ensure that the preparation and review of journal entries to accrue for costs include a review for duplicate costs.
Views of Responsible Officials and Corrective Action Plan - The City will review its journal entry controls and processes to help ensure journal entries are posted accurately and implement a review for duplicate costs.
Assistance Listing Number, Federal Agency, and Program Name - 14.218, Department of Housing and Urban Development, CDBG Entitlement Grants Cluster - Community Development Block Grant/Entitlement Grants (CDBG)
14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With Aids (HOPWA)
14.905, Department of Housing and Urban Development, Lead Hazard Reduction Demonstration Grant Program (Lead)
Federal Award Identification Number and Year -
CDBG - B-22-MC-26-0006
HOPWA - MIH22F001
Lead - MILNG0007-19, and MILHB0682-18
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), nonfederal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Per 2 CFR 200.403(9), costs must be adequately documented.
Condition - The City duplicated costs charged to certain grants.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Refer to context below
Context - In conjunction with the year-end close process, the City manually reviews invoices received subsequent to year end and identifies amounts to be accrued. These amounts are accrued via manual journal entries posted to period 13. As this is a period 13 entry, the amounts automatically reverse in the new year. During this process, the City duplicated costs to be accrued in the amount of $12,300 under ALN 14.218 (CDBG), $327,709 under ALN 14.241 (HOPWA), and $235,911 under ALN 14.905 (Lead). Despite being accrued, the City did not request reimbursement for these costs, as reimbursement is only requested after expenses are paid. Upon identification of the error, the City reduced the amounts reported on the schedule of expenditures of federal awards (SEFA) by the amounts noted above.
Cause and Effect - The City's control regarding the year-end close process did not identify that certain costs accrued were duplicated. As a result, the initial SEFA provided to the auditors was overstated by these costs. The City excluded the duplicate costs from the final
SEFA.
Recommendation - We recommend the City review its processes and controls to ensure that the preparation and review of journal entries to accrue for costs include a review for duplicate costs.
Views of Responsible Officials and Corrective Action Plan - The City will review its journal entry controls and processes to help ensure journal entries are posted accurately and implement a review for duplicate costs.
Assistance Listing Number, Federal Agency, and Program Name - 14.218, Department of Housing and Urban Development, CDBG Entitlement Grants Cluster - Community Development Block Grant/Entitlement Grants (CDBG)
14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With Aids (HOPWA)
14.905, Department of Housing and Urban Development, Lead Hazard Reduction Demonstration Grant Program (Lead)
Federal Award Identification Number and Year -
CDBG - B-22-MC-26-0006
HOPWA - MIH22F001
Lead - MILNG0007-19, and MILHB0682-18
Pass-through Entity - N/A
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), nonfederal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Per 2 CFR 200.403(9), costs must be adequately documented.
Condition - The City duplicated costs charged to certain grants.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - Refer to context below
Context - In conjunction with the year-end close process, the City manually reviews invoices received subsequent to year end and identifies amounts to be accrued. These amounts are accrued via manual journal entries posted to period 13. As this is a period 13 entry, the amounts automatically reverse in the new year. During this process, the City duplicated costs to be accrued in the amount of $12,300 under ALN 14.218 (CDBG), $327,709 under ALN 14.241 (HOPWA), and $235,911 under ALN 14.905 (Lead). Despite being accrued, the City did not request reimbursement for these costs, as reimbursement is only requested after expenses are paid. Upon identification of the error, the City reduced the amounts reported on the schedule of expenditures of federal awards (SEFA) by the amounts noted above.
Cause and Effect - The City's control regarding the year-end close process did not identify that certain costs accrued were duplicated. As a result, the initial SEFA provided to the auditors was overstated by these costs. The City excluded the duplicate costs from the final
SEFA.
Recommendation - We recommend the City review its processes and controls to ensure that the preparation and review of journal entries to accrue for costs include a review for duplicate costs.
Views of Responsible Officials and Corrective Action Plan - The City will review its journal entry controls and processes to help ensure journal entries are posted accurately and implement a review for duplicate costs.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.905, United States Department of Housing and Urban Development, Lead Hazard Reduction Demonstration Grant Program
Federal Award Identification Number and Year - MILHD0487-22, MILNG00007-19, MILHB0682-18, program years 2022, 2019, and 2018
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Additionally, per 2 CFR 200.303(b), the nonfederal entity must comply with the U.S. Constitution, federal statutes, regulations, and the terms and conditions of the federal award.
Condition - Certain controls in place did not operate effectively specific to eligibility, earmarking, and reporting compliance requirements.
Certain controls in place were not effective either because of design flaws or due to the lack of fully implemented controls. Our testing revealed that control design flaws existed and certain controls did not operate effectively during the fiscal year.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Controls must be designed effectively in order to be effective. The controls in place for eligibility and earmarking were not designed effectively. For the year ended June 30, 2023, the controls were neither designed to ensure supervisory review and approval of applicants' eligibility nor designed to ensure at least 90 percent of the total number of owner-occupied units assisted have a child occupant under six years of age.
Additionally, controls did not operate effectively to ensure that performance reports submitted agreed to underlying records and/or supporting documentation. For one of the three reports selected for testing, the City overstated the number of units that received evaluations based on the underlying support. The report indicated 19 units received evaluations, while the underlying support showed 10 units.
Cause and Effect - Without adequate controls in place over eligibility determinations and earmarking, ineligible participants could receive program benefits or the City could exceed the 10 percent allowance to provide support for applicants who do not have a child under the age of six, resulting in disallowed costs. Inadequate controls in place over reporting could result in noncompliance with the terms and conditions of the award and could lead to inappropriate decision-making.
Recommendation - We recommend the City maintain on file all terms and conditions outlined by the funding agency. Additionally, we recommend the City review the controls in place for the Lead Hazard Reduction Demonstration Grant Program to ensure that controls are designed effectively and implemented to address the risks of noncompliance identified by the City.
Views of Responsible Officials and Planned Corrective Actions - The City will review its processes and implement additional controls and the required review of eligibility approval is in place and all supporting documentation is stored and maintained.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.905, United States Department of Housing and Urban Development, Lead Hazard Reduction Demonstration Grant Program
Federal Award Identification Number and Year - MILHD0487-22, MILNG00007-19, MILHB0682-18, program years 2022, 2019, and 2018
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Additionally, per 2 CFR 200.303(b), the nonfederal entity must comply with the U.S. Constitution, federal statutes, regulations, and the terms and conditions of the federal award.
Condition - Certain controls in place did not operate effectively specific to eligibility, earmarking, and reporting compliance requirements.
Certain controls in place were not effective either because of design flaws or due to the lack of fully implemented controls. Our testing revealed that control design flaws existed and certain controls did not operate effectively during the fiscal year.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Controls must be designed effectively in order to be effective. The controls in place for eligibility and earmarking were not designed effectively. For the year ended June 30, 2023, the controls were neither designed to ensure supervisory review and approval of applicants' eligibility nor designed to ensure at least 90 percent of the total number of owner-occupied units assisted have a child occupant under six years of age.
Additionally, controls did not operate effectively to ensure that performance reports submitted agreed to underlying records and/or supporting documentation. For one of the three reports selected for testing, the City overstated the number of units that received evaluations based on the underlying support. The report indicated 19 units received evaluations, while the underlying support showed 10 units.
Cause and Effect - Without adequate controls in place over eligibility determinations and earmarking, ineligible participants could receive program benefits or the City could exceed the 10 percent allowance to provide support for applicants who do not have a child under the age of six, resulting in disallowed costs. Inadequate controls in place over reporting could result in noncompliance with the terms and conditions of the award and could lead to inappropriate decision-making.
Recommendation - We recommend the City maintain on file all terms and conditions outlined by the funding agency. Additionally, we recommend the City review the controls in place for the Lead Hazard Reduction Demonstration Grant Program to ensure that controls are designed effectively and implemented to address the risks of noncompliance identified by the City.
Views of Responsible Officials and Planned Corrective Actions - The City will review its processes and implement additional controls and the required review of eligibility approval is in place and all supporting documentation is stored and maintained.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.905, United States Department of Housing and Urban Development, Lead Hazard Reduction Demonstration Grant Program
Federal Award Identification Number and Year - MILHD0487-22, MILNG00007-19, MILHB0682-18, program years 2022, 2019, and 2018
Pass-through Entity - N/A
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal 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).
Additionally, per 2 CFR 200.303(b), the nonfederal entity must comply with the U.S. Constitution, federal statutes, regulations, and the terms and conditions of the federal award.
Condition - Certain controls in place did not operate effectively specific to eligibility, earmarking, and reporting compliance requirements.
Certain controls in place were not effective either because of design flaws or due to the lack of fully implemented controls. Our testing revealed that control design flaws existed and certain controls did not operate effectively during the fiscal year.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Controls must be designed effectively in order to be effective. The controls in place for eligibility and earmarking were not designed effectively. For the year ended June 30, 2023, the controls were neither designed to ensure supervisory review and approval of applicants' eligibility nor designed to ensure at least 90 percent of the total number of owner-occupied units assisted have a child occupant under six years of age.
Additionally, controls did not operate effectively to ensure that performance reports submitted agreed to underlying records and/or supporting documentation. For one of the three reports selected for testing, the City overstated the number of units that received evaluations based on the underlying support. The report indicated 19 units received evaluations, while the underlying support showed 10 units.
Cause and Effect - Without adequate controls in place over eligibility determinations and earmarking, ineligible participants could receive program benefits or the City could exceed the 10 percent allowance to provide support for applicants who do not have a child under the age of six, resulting in disallowed costs. Inadequate controls in place over reporting could result in noncompliance with the terms and conditions of the award and could lead to inappropriate decision-making.
Recommendation - We recommend the City maintain on file all terms and conditions outlined by the funding agency. Additionally, we recommend the City review the controls in place for the Lead Hazard Reduction Demonstration Grant Program to ensure that controls are designed effectively and implemented to address the risks of noncompliance identified by the City.
Views of Responsible Officials and Planned Corrective Actions - The City will review its processes and implement additional controls and the required review of eligibility approval is in place and all supporting documentation is stored and maintained.