Audit 304261

2023-002 Federal Agency: U.S. Department of the Treasury Program/Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Pass-through: N/A Award No. and Year: N/A, 2022 Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the review of required reports. Condition: We identified 1 instance in which the City did not document the review of the annual Project and Expenditure Report prior to submission. Cause: The report submission portal does not require an approval by an individual other than the individual that entered the report data. The City’s procedures did not include documenting the review by an individual other than the preparer. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted to the granting agency. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: 100% of the annual Project and Expenditure Reports were selected for testing. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the City revise its procedures to include evidence to document the individual who reviewed required reports prior to submission. Views of Responsible Officials and Planned Corrective Action: Management concurs with the finding. See separate corrective action plan.

2023-003 Federal Agency: U.S. Department of the Treasury Program/Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Pass-through: N/A Award No. and Year: N/A, 2022 Compliance Requirement: Procurement, suspension and debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance, Instance of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, 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 statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300. Condition: In 1 instance out of 4 procurements sampled, we could not evidence that management had reviewed the debarment status of a vendor at the time of entering into the contract/agreement, and the agreement did not include a clause regarding debarment status, nor did management obtain a certification of the vendor’s status from the vendor. Cause: The contract/agreement template used by the City did not include the debarment status clause, and management described that a debarment status check was performed on sam.gov at the time of entering into the agreement; however, the project manager overseeing the agreement who retained that documentation is no longer working for the City, and management could not locate the record of the debarment status check being performed. Effect: Entering into contracts with vendors could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None noted. Context/Sampling: A nonstatistical sample of 4 out of 8 contracts were selected. We found that none of the selected vendors were suspended or debarred. Repeat Finding from Prior Year: No. Recommendation: We recommend that the City review its procedures for retaining documentation evidencing the debarment status verifications performed for contracts and agreements through sam.gov. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See separate corrective action plan.

2023-002 Federal Agency: U.S. Department of the Treasury Program/Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Pass-through: N/A Award No. and Year: N/A, 2022 Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the review of required reports. Condition: We identified 1 instance in which the City did not document the review of the annual Project and Expenditure Report prior to submission. Cause: The report submission portal does not require an approval by an individual other than the individual that entered the report data. The City’s procedures did not include documenting the review by an individual other than the preparer. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted to the granting agency. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: 100% of the annual Project and Expenditure Reports were selected for testing. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the City revise its procedures to include evidence to document the individual who reviewed required reports prior to submission. Views of Responsible Officials and Planned Corrective Action: Management concurs with the finding. See separate corrective action plan.

2023-003 Federal Agency: U.S. Department of the Treasury Program/Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Pass-through: N/A Award No. and Year: N/A, 2022 Compliance Requirement: Procurement, suspension and debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance, Instance of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, 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 statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300. Condition: In 1 instance out of 4 procurements sampled, we could not evidence that management had reviewed the debarment status of a vendor at the time of entering into the contract/agreement, and the agreement did not include a clause regarding debarment status, nor did management obtain a certification of the vendor’s status from the vendor. Cause: The contract/agreement template used by the City did not include the debarment status clause, and management described that a debarment status check was performed on sam.gov at the time of entering into the agreement; however, the project manager overseeing the agreement who retained that documentation is no longer working for the City, and management could not locate the record of the debarment status check being performed. Effect: Entering into contracts with vendors could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None noted. Context/Sampling: A nonstatistical sample of 4 out of 8 contracts were selected. We found that none of the selected vendors were suspended or debarred. Repeat Finding from Prior Year: No. Recommendation: We recommend that the City review its procedures for retaining documentation evidencing the debarment status verifications performed for contracts and agreements through sam.gov. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See separate corrective action plan.