Assistance Listings number and name: 14.195 Section 8 Project-Based ClusterAward number and year: AZ99RF00001, December 1, 2017 through December 1, 2037Federal agency: U.S. Department of Housing and Urban DevelopmentCompliance requirement: Special tests and provisions-Housing quality standardsQuestioned costs: NoneCondition?During our testing, we noted the Authority did not have adequate internal controls designed to ensure annual quality housing standard inspections were performed as they became due.Effect?The Authority is not in compliance with program requirements for inspections.Cause?The Authority was unaware the housing units were due for their bi-annual housing quality inspection.Criteria?2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of Housing Quality Standards Inspections. The Authority should have internal controls designed to ensure compliance with those provisions.Recommendations?We recommend the Authority design controls to ensure an adequate internal control process is in place to identify the units on which housing quality inspections are due and properly document the result of these inspections.The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Assistance Listings number and name: 14.231 COVID-19 - Emergency Solutions Grant ProgramAward numbers and years: E-21-UC-04-0501, August 9, 2021 through August 8, 2023E-20-UW-04-0501 August 27, 2020 through November 22, 2022Federal agency: U.S. Department of Housing and Urban DevelopmentCompliance requirement: Special tests and provisions?Obligation, expenditure and payment requirementsQuestioned costs: Not applicableCondition?Contrary to federal regulation and the County?s award terms, the County?s Human Services Department did not pay subrecipients for program expenditures they incurred and requested reimbursement for within the required 30 days for 42 percent of the requests we tested. Specifically, of the 12 subrecipient reimbursement requests we tested, the Department paid 5 of those requests, totaling $78,992, 10 to 51 days late. This amount comprised 7.8 percent of total program expenditures the County reimbursed to subrecipients for the year and 3.4 percent of total program expenditures the County incurred for the year.Effect?The Department?s failure to pay subrecipients within the required 30 days may place an undue financial burden on those entities, which are primarily nonprofit organizations that are helping the County administer the federal program, placing the services provided by those entities at an increased risk of being interrupted.Cause?The Department reported it needed additional time to obtain complete reimbursement requests from its subrecipients; however, the Department did not document its attempts to obtain complete requests or the dates when the completed requests were obtained. Further, the Department did not have written policies and procedures for paying subrecipients within the required 30-day period.Criteria?Both federal regulation and the County?s award terms require the County to pay subrecipients for allowable costs they incur for the program within 30 days of receiving their completed reimbursement requests (24 Code of Federal Regulation [CFR] ?576.203). In addition, the County must establish and maintain effective internal control over federal awards that provides reasonable assurance that federal programs are being administered in compliance with all applicable laws, regulations, and award terms (2 CFR 200.303).Recommendations?The Department should:1. Develop and implement written policies and procedures to pay subrecipients for program expenditures they incur and request reimbursement for within the required 30 days of receiving their completed reimbursement requests.2. Document its attempts to obtain complete reimbursement requests from subrecipients or the dates when the completed requests were obtained.The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Assistance Listings number and name: 14.231 COVID-19 - Emergency Solutions Grant ProgramAward numbers and years: E-21-UC-04-0501, August 9, 2021 through August 8, 2023E-20-UW-04-0501 August 27, 2020 through November 22, 2022Federal agency: U.S. Department of Housing and Urban DevelopmentCompliance requirement: Special tests and provisions?Obligation, expenditure and payment requirementsQuestioned costs: Not applicableCondition?Contrary to federal regulation and the County?s award terms, the County?s Human Services Department did not pay subrecipients for program expenditures they incurred and requested reimbursement for within the required 30 days for 42 percent of the requests we tested. Specifically, of the 12 subrecipient reimbursement requests we tested, the Department paid 5 of those requests, totaling $78,992, 10 to 51 days late. This amount comprised 7.8 percent of total program expenditures the County reimbursed to subrecipients for the year and 3.4 percent of total program expenditures the County incurred for the year.Effect?The Department?s failure to pay subrecipients within the required 30 days may place an undue financial burden on those entities, which are primarily nonprofit organizations that are helping the County administer the federal program, placing the services provided by those entities at an increased risk of being interrupted.Cause?The Department reported it needed additional time to obtain complete reimbursement requests from its subrecipients; however, the Department did not document its attempts to obtain complete requests or the dates when the completed requests were obtained. Further, the Department did not have written policies and procedures for paying subrecipients within the required 30-day period.Criteria?Both federal regulation and the County?s award terms require the County to pay subrecipients for allowable costs they incur for the program within 30 days of receiving their completed reimbursement requests (24 Code of Federal Regulation [CFR] ?576.203). In addition, the County must establish and maintain effective internal control over federal awards that provides reasonable assurance that federal programs are being administered in compliance with all applicable laws, regulations, and award terms (2 CFR 200.303).Recommendations?The Department should:1. Develop and implement written policies and procedures to pay subrecipients for program expenditures they incur and request reimbursement for within the required 30 days of receiving their completed reimbursement requests.2. Document its attempts to obtain complete reimbursement requests from subrecipients or the dates when the completed requests were obtained.The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Assistance Listings number and name: 21.023 COVID-19 - Emergency Rental Assistance ProgramAward numbers and years: C-95-21-017-X-01, January 6, 2021 through September 30, 2022;C 22-22-062-X-00, December 6, 2021 through June 30, 2024; C 49-21-024-X-00, May 10, 2021 through September 30, 2025Federal agency: U.S. TreasuryCompliance requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and EligibilityQuestioned costs: $60,199Condition?During the audit, County management reported to us that it identified 6 suspicious payments totaling $135,125 that it made to potentially fraudulent claimants during fiscal year 2022. We reviewed each of the 6 suspicious payments the County made and determined each involved a rental assistance application listing a landlord who was not the recorded property owner of the residence. Although we did not identify instances in which the landlord was not the residence?s property owner in the sample of 60 applications we tested, the County potentially made improper payments from the $75.8 million it disbursed for emergency rental assistance during the year due to the County?s Human Services Department not verifying the landlord information provided on the application.Effect?Upon making potential improper payments, the County made those monies no longer available to assist others who may have needed emergency rental assistance and would have been eligible to receive it. Three of the 6 potentially improper payments totaling $74,926 were flagged by banks and a reported landlord and returned to the County due to suspicious activity, and County management used those monies to provide emergency rental assistance payments to other claimants. However, the County is at risk of having to repay any unrecovered payments that the federal government determines to be improper.Cause?Although the Department had written policies and procedures for verifying tenants were eligible to participate in other federal and State assistance welfare programs before making payments to them, it lacked guidance to identify fraud indicators for applicant information that may warrant further investigation and where to implement antifraud measures to address the program?s inherent risks. For instance, the Department relied on written attestations from applicants that the landlord information provided was accurate but lacked written procedures to verify information submitted on applications using other County records, such as matching the landlord on the application to the County Assessor?s records of the residence?s property owner. In September 2022, the Department began implementing written procedures to verify landlord information with the County Assessor?s property records.Criteria?Federal law and the County?s grant award terms and policies and procedures all require the Department to make rental assistance payments for eligible household tenants directly to the tenant?s landlord unless documentation is provided indicating that the landlord refuses to participate in the program and accept the payments on the tenant?s behalf.1 In those cases, the Department may make payments directly to the tenant. In addition, the County must establish and maintain effective internal control over federal awards that provides reasonable assurance that federal programs are being administered in compliance with all applicable laws, regulations, and award terms (2 CFR 200.303).Recommendations?The Department should:1. Continue to verify that the landlord information provided in the application is accurate prior to authorizing rental assistance payments, such as by verifying landlord information with the County Assessor?s property record.2. Add written policies and procedures to include guidance to identify fraud indicators for applicant information that may warrant further investigation and where to implement antifraud measures to address the program?s inherent risks.3. Investigate suspicious payments and work with the federal grantor, its legal counsel, and law enforcement, as appropriate, to recover any payments determined to be improper.4. Repay any unrecovered monies to the federal grantor, if required.The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.1 The Consolidated Appropriations Act of 2021 (Public Law 116-260), Title V, Section 501(c)(2)(C)(i)(l) and the American Rescue Plan Act of 2021 (Public Law 117-2), Title III, Section 3201.
Assistance Listings number and name: 84.374 Teacher and School Leader Incentive GrantsAward number and year: U374A160041-20, October 1, 2020 through September 30, 2022Federal agency: U.S. Department of EducationCompliance requirement: Cash managementQuestioned costs: $925,524Condition?Contrary to federal regulation, the Maricopa County School Superintendent?s Office overdrew $1,370,113 of program monies for its May 2022 reimbursement request for program expenditures it did not incur, or 18 percent of the program?s total expenditures for the year.Effect?The Office risks having to return the $1,370,113 of program monies for expenditures that it had not incurred and was not eligible to receive, along with any interest it earned exceeding $500, to the federal grantor. However, the Office incurred additional program expenditures of $444,589 during the fiscal year for which it did not request reimbursement because it wanted to first resolve the $1,370,113 overdrawn amount. Therefore, the total questioned costs at fiscal year-end were $925,524, which the Office reported notifying the federal grantor of the error and requesting guidance on how to repay the federal monies. The federal program ended on September 30, 2022, and the Office will need to work with the federal grantor to resolve the overpayment during the grant?s close-out.Cause?The Office?s former Assistant Superintendent incorrectly based the May 2022 drawdown on the wrong time period?July 1, 2019 through May 2020 instead of the time period of July 1, 2021 through May 2022, resulting in a requested drawdown of $1,915,288 rather than the needed drawdown of $545,175?due to an apparent oversight. The Office?s policies and procedures did not require the reviewer to perform a reconciliation of the year?s program expenditures to the drawdown request prior to approving the request for submission to the federal grantor, and the assigned reviewer did not detect the error. Had the Office performed a more careful preparation and detailed review of the reimbursement request, it may have been able to detect and correct the error before submitting the reimbursement request to the federal grantor.Criteria?The Office?s federal award terms and federal Uniform Guidance require the Office to use the reimbursement method to administer the program, whereby the Office is reimbursed with federal program monies only after it spends its own monies for authorized program purposes and requests reimbursement from the federal grantor (2 Code of Federal Regulations [CFR] ?200.305[b][3]). Accordingly, both the Office and County-wide policies and procedures require an independent review and approval of federal program reimbursement requests and reports before submitting them to the grantor. Also, federal regulation requires the County and all its departments administering federal grants to establish and maintain effective internal control over federal awards that provides reasonable assurance that federal programs are being administered in accordance with all applicable laws, regulations, and award terms (2 CFR ?200.303).Recommendations?The Office should develop and implement policies and procedures for preparing and reviewing federal reimbursement requests that require:1. The assigned reimbursement request reviewer to review or reconcile program expenditures recorded on the County?s financial accounting system to the drawdown request before approving the request to be submitted to the federal grantor.2. The Office to continue to work with the federal grantor to repay award amounts exceeding what the Office was eligible to receive, if any such amounts exist during the grant's close-out.The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Assistance Listings number and name: 14.195 Section 8 Project-Based ClusterAward number and year: AZ99RF00001, December 1, 2017 through December 1, 2037Federal agency: U.S. Department of Housing and Urban DevelopmentCompliance requirement: Special tests and provisions-Housing quality standardsQuestioned costs: NoneCondition?During our testing, we noted the Authority did not have adequate internal controls designed to ensure annual quality housing standard inspections were performed as they became due.Effect?The Authority is not in compliance with program requirements for inspections.Cause?The Authority was unaware the housing units were due for their bi-annual housing quality inspection.Criteria?2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of Housing Quality Standards Inspections. The Authority should have internal controls designed to ensure compliance with those provisions.Recommendations?We recommend the Authority design controls to ensure an adequate internal control process is in place to identify the units on which housing quality inspections are due and properly document the result of these inspections.The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Assistance Listings number and name: 14.231 COVID-19 - Emergency Solutions Grant ProgramAward numbers and years: E-21-UC-04-0501, August 9, 2021 through August 8, 2023E-20-UW-04-0501 August 27, 2020 through November 22, 2022Federal agency: U.S. Department of Housing and Urban DevelopmentCompliance requirement: Special tests and provisions?Obligation, expenditure and payment requirementsQuestioned costs: Not applicableCondition?Contrary to federal regulation and the County?s award terms, the County?s Human Services Department did not pay subrecipients for program expenditures they incurred and requested reimbursement for within the required 30 days for 42 percent of the requests we tested. Specifically, of the 12 subrecipient reimbursement requests we tested, the Department paid 5 of those requests, totaling $78,992, 10 to 51 days late. This amount comprised 7.8 percent of total program expenditures the County reimbursed to subrecipients for the year and 3.4 percent of total program expenditures the County incurred for the year.Effect?The Department?s failure to pay subrecipients within the required 30 days may place an undue financial burden on those entities, which are primarily nonprofit organizations that are helping the County administer the federal program, placing the services provided by those entities at an increased risk of being interrupted.Cause?The Department reported it needed additional time to obtain complete reimbursement requests from its subrecipients; however, the Department did not document its attempts to obtain complete requests or the dates when the completed requests were obtained. Further, the Department did not have written policies and procedures for paying subrecipients within the required 30-day period.Criteria?Both federal regulation and the County?s award terms require the County to pay subrecipients for allowable costs they incur for the program within 30 days of receiving their completed reimbursement requests (24 Code of Federal Regulation [CFR] ?576.203). In addition, the County must establish and maintain effective internal control over federal awards that provides reasonable assurance that federal programs are being administered in compliance with all applicable laws, regulations, and award terms (2 CFR 200.303).Recommendations?The Department should:1. Develop and implement written policies and procedures to pay subrecipients for program expenditures they incur and request reimbursement for within the required 30 days of receiving their completed reimbursement requests.2. Document its attempts to obtain complete reimbursement requests from subrecipients or the dates when the completed requests were obtained.The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Assistance Listings number and name: 14.231 COVID-19 - Emergency Solutions Grant ProgramAward numbers and years: E-21-UC-04-0501, August 9, 2021 through August 8, 2023E-20-UW-04-0501 August 27, 2020 through November 22, 2022Federal agency: U.S. Department of Housing and Urban DevelopmentCompliance requirement: Special tests and provisions?Obligation, expenditure and payment requirementsQuestioned costs: Not applicableCondition?Contrary to federal regulation and the County?s award terms, the County?s Human Services Department did not pay subrecipients for program expenditures they incurred and requested reimbursement for within the required 30 days for 42 percent of the requests we tested. Specifically, of the 12 subrecipient reimbursement requests we tested, the Department paid 5 of those requests, totaling $78,992, 10 to 51 days late. This amount comprised 7.8 percent of total program expenditures the County reimbursed to subrecipients for the year and 3.4 percent of total program expenditures the County incurred for the year.Effect?The Department?s failure to pay subrecipients within the required 30 days may place an undue financial burden on those entities, which are primarily nonprofit organizations that are helping the County administer the federal program, placing the services provided by those entities at an increased risk of being interrupted.Cause?The Department reported it needed additional time to obtain complete reimbursement requests from its subrecipients; however, the Department did not document its attempts to obtain complete requests or the dates when the completed requests were obtained. Further, the Department did not have written policies and procedures for paying subrecipients within the required 30-day period.Criteria?Both federal regulation and the County?s award terms require the County to pay subrecipients for allowable costs they incur for the program within 30 days of receiving their completed reimbursement requests (24 Code of Federal Regulation [CFR] ?576.203). In addition, the County must establish and maintain effective internal control over federal awards that provides reasonable assurance that federal programs are being administered in compliance with all applicable laws, regulations, and award terms (2 CFR 200.303).Recommendations?The Department should:1. Develop and implement written policies and procedures to pay subrecipients for program expenditures they incur and request reimbursement for within the required 30 days of receiving their completed reimbursement requests.2. Document its attempts to obtain complete reimbursement requests from subrecipients or the dates when the completed requests were obtained.The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Assistance Listings number and name: 21.023 COVID-19 - Emergency Rental Assistance ProgramAward numbers and years: C-95-21-017-X-01, January 6, 2021 through September 30, 2022;C 22-22-062-X-00, December 6, 2021 through June 30, 2024; C 49-21-024-X-00, May 10, 2021 through September 30, 2025Federal agency: U.S. TreasuryCompliance requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and EligibilityQuestioned costs: $60,199Condition?During the audit, County management reported to us that it identified 6 suspicious payments totaling $135,125 that it made to potentially fraudulent claimants during fiscal year 2022. We reviewed each of the 6 suspicious payments the County made and determined each involved a rental assistance application listing a landlord who was not the recorded property owner of the residence. Although we did not identify instances in which the landlord was not the residence?s property owner in the sample of 60 applications we tested, the County potentially made improper payments from the $75.8 million it disbursed for emergency rental assistance during the year due to the County?s Human Services Department not verifying the landlord information provided on the application.Effect?Upon making potential improper payments, the County made those monies no longer available to assist others who may have needed emergency rental assistance and would have been eligible to receive it. Three of the 6 potentially improper payments totaling $74,926 were flagged by banks and a reported landlord and returned to the County due to suspicious activity, and County management used those monies to provide emergency rental assistance payments to other claimants. However, the County is at risk of having to repay any unrecovered payments that the federal government determines to be improper.Cause?Although the Department had written policies and procedures for verifying tenants were eligible to participate in other federal and State assistance welfare programs before making payments to them, it lacked guidance to identify fraud indicators for applicant information that may warrant further investigation and where to implement antifraud measures to address the program?s inherent risks. For instance, the Department relied on written attestations from applicants that the landlord information provided was accurate but lacked written procedures to verify information submitted on applications using other County records, such as matching the landlord on the application to the County Assessor?s records of the residence?s property owner. In September 2022, the Department began implementing written procedures to verify landlord information with the County Assessor?s property records.Criteria?Federal law and the County?s grant award terms and policies and procedures all require the Department to make rental assistance payments for eligible household tenants directly to the tenant?s landlord unless documentation is provided indicating that the landlord refuses to participate in the program and accept the payments on the tenant?s behalf.1 In those cases, the Department may make payments directly to the tenant. In addition, the County must establish and maintain effective internal control over federal awards that provides reasonable assurance that federal programs are being administered in compliance with all applicable laws, regulations, and award terms (2 CFR 200.303).Recommendations?The Department should:1. Continue to verify that the landlord information provided in the application is accurate prior to authorizing rental assistance payments, such as by verifying landlord information with the County Assessor?s property record.2. Add written policies and procedures to include guidance to identify fraud indicators for applicant information that may warrant further investigation and where to implement antifraud measures to address the program?s inherent risks.3. Investigate suspicious payments and work with the federal grantor, its legal counsel, and law enforcement, as appropriate, to recover any payments determined to be improper.4. Repay any unrecovered monies to the federal grantor, if required.The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.1 The Consolidated Appropriations Act of 2021 (Public Law 116-260), Title V, Section 501(c)(2)(C)(i)(l) and the American Rescue Plan Act of 2021 (Public Law 117-2), Title III, Section 3201.
Assistance Listings number and name: 84.374 Teacher and School Leader Incentive GrantsAward number and year: U374A160041-20, October 1, 2020 through September 30, 2022Federal agency: U.S. Department of EducationCompliance requirement: Cash managementQuestioned costs: $925,524Condition?Contrary to federal regulation, the Maricopa County School Superintendent?s Office overdrew $1,370,113 of program monies for its May 2022 reimbursement request for program expenditures it did not incur, or 18 percent of the program?s total expenditures for the year.Effect?The Office risks having to return the $1,370,113 of program monies for expenditures that it had not incurred and was not eligible to receive, along with any interest it earned exceeding $500, to the federal grantor. However, the Office incurred additional program expenditures of $444,589 during the fiscal year for which it did not request reimbursement because it wanted to first resolve the $1,370,113 overdrawn amount. Therefore, the total questioned costs at fiscal year-end were $925,524, which the Office reported notifying the federal grantor of the error and requesting guidance on how to repay the federal monies. The federal program ended on September 30, 2022, and the Office will need to work with the federal grantor to resolve the overpayment during the grant?s close-out.Cause?The Office?s former Assistant Superintendent incorrectly based the May 2022 drawdown on the wrong time period?July 1, 2019 through May 2020 instead of the time period of July 1, 2021 through May 2022, resulting in a requested drawdown of $1,915,288 rather than the needed drawdown of $545,175?due to an apparent oversight. The Office?s policies and procedures did not require the reviewer to perform a reconciliation of the year?s program expenditures to the drawdown request prior to approving the request for submission to the federal grantor, and the assigned reviewer did not detect the error. Had the Office performed a more careful preparation and detailed review of the reimbursement request, it may have been able to detect and correct the error before submitting the reimbursement request to the federal grantor.Criteria?The Office?s federal award terms and federal Uniform Guidance require the Office to use the reimbursement method to administer the program, whereby the Office is reimbursed with federal program monies only after it spends its own monies for authorized program purposes and requests reimbursement from the federal grantor (2 Code of Federal Regulations [CFR] ?200.305[b][3]). Accordingly, both the Office and County-wide policies and procedures require an independent review and approval of federal program reimbursement requests and reports before submitting them to the grantor. Also, federal regulation requires the County and all its departments administering federal grants to establish and maintain effective internal control over federal awards that provides reasonable assurance that federal programs are being administered in accordance with all applicable laws, regulations, and award terms (2 CFR ?200.303).Recommendations?The Office should develop and implement policies and procedures for preparing and reviewing federal reimbursement requests that require:1. The assigned reimbursement request reviewer to review or reconcile program expenditures recorded on the County?s financial accounting system to the drawdown request before approving the request to be submitted to the federal grantor.2. The Office to continue to work with the federal grantor to repay award amounts exceeding what the Office was eligible to receive, if any such amounts exist during the grant's close-out.The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.