Audit 31085

Monitoring and Reporting Program Performance Criteria ? Title 2, U.S. Code of Federal Regulations Part 200.329 Monitoring and Reporting Program Performance, the City was required to submit Non-construction performance reports (1) The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. ?The recipient is responsible for completing and submitting a Programmatic Performance Report (PPR) using FEMA GO?. Condition ? The City?s management did not submit the PPR on a timely basis. Cause ? The City?s management were not aware that they needed to submit the PPR on a quarterly basis. Effect ? The City is not in compliance with Federal regulations pertaining to monitoring and reporting program performance as required by the Uniform Guidance. Recommendation ? The City should submit the PPR on a timely basis. Corrective Action ? The City has submitted the PPR after being notified by FEM and will continue to submit on time. Conclusion ? Response accepted.

Procurement Suspension & Debarment Criteria ? Title 2, U.S. Code of Federal Regulations Part 180.300 When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition ? The City?s management did not verify that the vendor was not suspended or disbarred. Cause ?The City?s management were not aware that they needed to verify that the entity was not suspended or debarred. Effect ? The City did not have a process to indicate that the vendor was not suspended or disbarred from doing business with federal funds. The City is not in compliance with Federal regulations pertaining to procurement suspension & debarment as required by the Uniform Guidance. Recommendation ? The City should verify that each vendor or contracts paid with federal awards, are not suspended by checking the System for Awards Management (SAM) Exclusion available at SAM.gov. Corrective Action ? The City was unable to check to make sure the contractor was not disbarred from federal grants. The City is working through a process to ensure all contractors are not on the disbarred list. This requirement is infrequent and may not come to the city for several years. The City will check SAMS numbers and do more work on the front end for each contractor Conclusion ? Response accepted.

Single Audit Process Criteria ? Title 2, U.S. Code of Federal Regulations ?200.501 states that an entity that expends $750,000 or more during the non-Federal entity?s fiscal year in Federal awards, they must have a single audit or program-specific audit conducted for that year in accordance with the provision in ?200.501. Condition ? The City had over $750,000 in federal expenditures in the current year and did not request an audit in accordance with Uniform Guidance. Cause ?The City?s management did not track expenditures of federal awards for the year ended June 30, 2022 to determine what federal audit requirements applied if any. Were it not for our recommendation that an Audit in accordance with Uniform Guidance was required, it may have been missed. Effect ? The City?s internal control over compliance with federal audit requirements was inadequate. Recommendation ? The City should establish a process to track the dollar amount of federal expenditures that were spent during the year to determine if an audit in accordance with uniform guidance is required. This should be done and communicated with the auditors before audit work begins. Corrective Action ? The City will work on a formal process for tracking all federal grants. The city has always been cognizant of this rule and did inform the auditors when the audit was being performed. The City Administrator feels strongly that this requirement was met. Conclusion ? Response accepted.

Monitoring and Reporting Program Performance Criteria ? Title 2, U.S. Code of Federal Regulations Part 200.329 Monitoring and Reporting Program Performance, the City was required to submit Non-construction performance reports (1) The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. ?The recipient is responsible for completing and submitting a Programmatic Performance Report (PPR) using FEMA GO?. Condition ? The City?s management did not submit the PPR on a timely basis. Cause ? The City?s management were not aware that they needed to submit the PPR on a quarterly basis. Effect ? The City is not in compliance with Federal regulations pertaining to monitoring and reporting program performance as required by the Uniform Guidance. Recommendation ? The City should submit the PPR on a timely basis. Corrective Action ? The City has submitted the PPR after being notified by FEM and will continue to submit on time. Conclusion ? Response accepted.

Procurement Suspension & Debarment Criteria ? Title 2, U.S. Code of Federal Regulations Part 180.300 When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition ? The City?s management did not verify that the vendor was not suspended or disbarred. Cause ?The City?s management were not aware that they needed to verify that the entity was not suspended or debarred. Effect ? The City did not have a process to indicate that the vendor was not suspended or disbarred from doing business with federal funds. The City is not in compliance with Federal regulations pertaining to procurement suspension & debarment as required by the Uniform Guidance. Recommendation ? The City should verify that each vendor or contracts paid with federal awards, are not suspended by checking the System for Awards Management (SAM) Exclusion available at SAM.gov. Corrective Action ? The City was unable to check to make sure the contractor was not disbarred from federal grants. The City is working through a process to ensure all contractors are not on the disbarred list. This requirement is infrequent and may not come to the city for several years. The City will check SAMS numbers and do more work on the front end for each contractor Conclusion ? Response accepted.

Single Audit Process Criteria ? Title 2, U.S. Code of Federal Regulations ?200.501 states that an entity that expends $750,000 or more during the non-Federal entity?s fiscal year in Federal awards, they must have a single audit or program-specific audit conducted for that year in accordance with the provision in ?200.501. Condition ? The City had over $750,000 in federal expenditures in the current year and did not request an audit in accordance with Uniform Guidance. Cause ?The City?s management did not track expenditures of federal awards for the year ended June 30, 2022 to determine what federal audit requirements applied if any. Were it not for our recommendation that an Audit in accordance with Uniform Guidance was required, it may have been missed. Effect ? The City?s internal control over compliance with federal audit requirements was inadequate. Recommendation ? The City should establish a process to track the dollar amount of federal expenditures that were spent during the year to determine if an audit in accordance with uniform guidance is required. This should be done and communicated with the auditors before audit work begins. Corrective Action ? The City will work on a formal process for tracking all federal grants. The city has always been cognizant of this rule and did inform the auditors when the audit was being performed. The City Administrator feels strongly that this requirement was met. Conclusion ? Response accepted.