Program: CDBG - Entitlement Grants Cluster
Assistance Listing Number: 14.218
Compliance Requirement: Reporting
Federal Agency: Department of Housing and Urban Development
Criteria or Specific Requirement – Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred to as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). In addition, CDBG Reporting requirements are established under 24 CFR Part 570.
Condition – The City did not report the subaward information for the fiscal year ended September 30, 2023. In addition, the City had material errors reported on the annual CDBG Financial Summary Report (PR26) and one PR29 – CDBG Cash on Hand Quarterly Report.
Questioned Costs – None
Context – The City’s only subaward more than $30,000 was selected for testing under the program. The City did not report the subaward information. In addition, 2 of the other 5 reports selected for testing had material errors on amounts reported. The sample was not intended to be, and was not, a statistically valid sample.
Effect – The City did not report the subaward information as required by the Uniform Guidance. In addition, required reports for federal awards had material errors.
Cause – The City did not have adequate controls or procedures in place to identify the applicable reporting requirements and ensure the required reports for federal awards include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with the Uniform Guidance.
Identification as a Repeat Finding – N/A
Recommendation – Management should implement policies and procedures to ensure required reports are completed accurately and filed by their respective due dates in accordance with the grant agreements and Uniform Guidance.
View of Responsible Officials and Planned Corrective Actions – We agree with the finding. See separate report for planned corrective actions.
Program: CDBG - Entitlement Grants Cluster
Assistance Listing Number: 14.218
Compliance Requirement: Reporting
Federal Agency: Department of Housing and Urban Development
Criteria or Specific Requirement – Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred to as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). In addition, CDBG Reporting requirements are established under 24 CFR Part 570.
Condition – The City did not report the subaward information for the fiscal year ended September 30, 2023. In addition, the City had material errors reported on the annual CDBG Financial Summary Report (PR26) and one PR29 – CDBG Cash on Hand Quarterly Report.
Questioned Costs – None
Context – The City’s only subaward more than $30,000 was selected for testing under the program. The City did not report the subaward information. In addition, 2 of the other 5 reports selected for testing had material errors on amounts reported. The sample was not intended to be, and was not, a statistically valid sample.
Effect – The City did not report the subaward information as required by the Uniform Guidance. In addition, required reports for federal awards had material errors.
Cause – The City did not have adequate controls or procedures in place to identify the applicable reporting requirements and ensure the required reports for federal awards include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with the Uniform Guidance.
Identification as a Repeat Finding – N/A
Recommendation – Management should implement policies and procedures to ensure required reports are completed accurately and filed by their respective due dates in accordance with the grant agreements and Uniform Guidance.
View of Responsible Officials and Planned Corrective Actions – We agree with the finding. See separate report for planned corrective actions.
Program: COVID-19 - Provider Relief Fund
Assistance Listing Number: 93.498
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs and Reporting
Federal Agency: Department of Health and Human Services
Criteria or Specific Requirement – Activities Allowed/Unallowed and Cost Principles (Pub. L. No. 116-136, 134 Stat. 563 and Pub. L. No. 116-139, 134 Stat. 622 and 623) and Reporting (45 CFR 75.342). Federal awards are only to be expended for allowable activities. In addition, the City is required to prepare and submit the period five provider relief fund report to the U.S. Department of Health and Human Services. This report is to be prepared using accurate financial information and submitted by the deadline established.
Condition – The City reported COVID-19-related expenditures, including supplies, within the HHS Provider Relief Fund (PRF) portal that did not have sufficient supporting documentation showing expenditures were related to the prevention, preparation or response to COVID-19. In addition, the City reported fringe benefit amounts based on budgeted allocations and not actual expenditures.
Questioned Costs – $163,700. Questioned costs were determined by the amount of allocated supplies and fringe benefit costs included within the federal awards expended.
Context – Management made certain estimates related to allowable program costs that did not have adequate underlying supporting documentation to determine proper allocation of claimed program expenditures.
Effect – The City submitted expenses under the PRF program based on allocations and not actual expenditures. As a result, the City did not have support that they were reasonably related to the prevention, preparation or response to COVID-19.
Cause – Internal controls were not in place to ensure federal awards were expended only for allowable activities.
Identification as a Repeat Finding – N/A
Recommendation – Policies and procedures over federal grant expenditure and reporting should be modified to ensure that allowable costs are supported by expenditures and reports that include indirect costs have sufficient supporting documentation that is retained in accordance with grant requirements.
Views of Responsible Officials and Planned Corrective Actions – We agree with the finding. See separate report for planned corrective actions.
Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Compliance Requirement: Procurement and Suspension and Debarment
Federal Agency: Department of the Treasury
Criteria or Specific Requirement – When a non-federal entity enters into a covered transaction with a vendor, the non-federal entity must verify that the vendor, 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 did not verify that a vendor was not suspended, debarred, or otherwise excluded from a covered transaction.
Questioned Costs - None
Context – The City did not verify that a vendor was not suspended, debarred, or otherwise excluded for one of the two covered transactions selected for testing. The sample was not intended to be, and was not, a statistically valid sample.
Effect – The City did not verify that a vendor was not suspended, debarred, or otherwise excluded for a covered transaction as required.
Cause – Internal controls over procurement were not in place to ensure the City verifies that vendors were not suspended, debarred, or otherwise excluded for a covered transaction.
Identification as a Repeat Finding – N/A
Recommendation – Policies and procedures should be modified to ensure the City verifies that vendors are not suspended, debarred, or otherwise excluded for a covered transaction.
Views of Responsible Officials and Planned Corrective Actions – We agree with the finding. See separate report for planned corrective actions.
Program: CDBG - Entitlement Grants Cluster
Assistance Listing Number: 14.218
Compliance Requirement: Reporting
Federal Agency: Department of Housing and Urban Development
Criteria or Specific Requirement – Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred to as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). In addition, CDBG Reporting requirements are established under 24 CFR Part 570.
Condition – The City did not report the subaward information for the fiscal year ended September 30, 2023. In addition, the City had material errors reported on the annual CDBG Financial Summary Report (PR26) and one PR29 – CDBG Cash on Hand Quarterly Report.
Questioned Costs – None
Context – The City’s only subaward more than $30,000 was selected for testing under the program. The City did not report the subaward information. In addition, 2 of the other 5 reports selected for testing had material errors on amounts reported. The sample was not intended to be, and was not, a statistically valid sample.
Effect – The City did not report the subaward information as required by the Uniform Guidance. In addition, required reports for federal awards had material errors.
Cause – The City did not have adequate controls or procedures in place to identify the applicable reporting requirements and ensure the required reports for federal awards include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with the Uniform Guidance.
Identification as a Repeat Finding – N/A
Recommendation – Management should implement policies and procedures to ensure required reports are completed accurately and filed by their respective due dates in accordance with the grant agreements and Uniform Guidance.
View of Responsible Officials and Planned Corrective Actions – We agree with the finding. See separate report for planned corrective actions.
Program: CDBG - Entitlement Grants Cluster
Assistance Listing Number: 14.218
Compliance Requirement: Reporting
Federal Agency: Department of Housing and Urban Development
Criteria or Specific Requirement – Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred to as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). In addition, CDBG Reporting requirements are established under 24 CFR Part 570.
Condition – The City did not report the subaward information for the fiscal year ended September 30, 2023. In addition, the City had material errors reported on the annual CDBG Financial Summary Report (PR26) and one PR29 – CDBG Cash on Hand Quarterly Report.
Questioned Costs – None
Context – The City’s only subaward more than $30,000 was selected for testing under the program. The City did not report the subaward information. In addition, 2 of the other 5 reports selected for testing had material errors on amounts reported. The sample was not intended to be, and was not, a statistically valid sample.
Effect – The City did not report the subaward information as required by the Uniform Guidance. In addition, required reports for federal awards had material errors.
Cause – The City did not have adequate controls or procedures in place to identify the applicable reporting requirements and ensure the required reports for federal awards include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with the Uniform Guidance.
Identification as a Repeat Finding – N/A
Recommendation – Management should implement policies and procedures to ensure required reports are completed accurately and filed by their respective due dates in accordance with the grant agreements and Uniform Guidance.
View of Responsible Officials and Planned Corrective Actions – We agree with the finding. See separate report for planned corrective actions.
Program: COVID-19 - Provider Relief Fund
Assistance Listing Number: 93.498
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs and Reporting
Federal Agency: Department of Health and Human Services
Criteria or Specific Requirement – Activities Allowed/Unallowed and Cost Principles (Pub. L. No. 116-136, 134 Stat. 563 and Pub. L. No. 116-139, 134 Stat. 622 and 623) and Reporting (45 CFR 75.342). Federal awards are only to be expended for allowable activities. In addition, the City is required to prepare and submit the period five provider relief fund report to the U.S. Department of Health and Human Services. This report is to be prepared using accurate financial information and submitted by the deadline established.
Condition – The City reported COVID-19-related expenditures, including supplies, within the HHS Provider Relief Fund (PRF) portal that did not have sufficient supporting documentation showing expenditures were related to the prevention, preparation or response to COVID-19. In addition, the City reported fringe benefit amounts based on budgeted allocations and not actual expenditures.
Questioned Costs – $163,700. Questioned costs were determined by the amount of allocated supplies and fringe benefit costs included within the federal awards expended.
Context – Management made certain estimates related to allowable program costs that did not have adequate underlying supporting documentation to determine proper allocation of claimed program expenditures.
Effect – The City submitted expenses under the PRF program based on allocations and not actual expenditures. As a result, the City did not have support that they were reasonably related to the prevention, preparation or response to COVID-19.
Cause – Internal controls were not in place to ensure federal awards were expended only for allowable activities.
Identification as a Repeat Finding – N/A
Recommendation – Policies and procedures over federal grant expenditure and reporting should be modified to ensure that allowable costs are supported by expenditures and reports that include indirect costs have sufficient supporting documentation that is retained in accordance with grant requirements.
Views of Responsible Officials and Planned Corrective Actions – We agree with the finding. See separate report for planned corrective actions.
Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Compliance Requirement: Procurement and Suspension and Debarment
Federal Agency: Department of the Treasury
Criteria or Specific Requirement – When a non-federal entity enters into a covered transaction with a vendor, the non-federal entity must verify that the vendor, 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 did not verify that a vendor was not suspended, debarred, or otherwise excluded from a covered transaction.
Questioned Costs - None
Context – The City did not verify that a vendor was not suspended, debarred, or otherwise excluded for one of the two covered transactions selected for testing. The sample was not intended to be, and was not, a statistically valid sample.
Effect – The City did not verify that a vendor was not suspended, debarred, or otherwise excluded for a covered transaction as required.
Cause – Internal controls over procurement were not in place to ensure the City verifies that vendors were not suspended, debarred, or otherwise excluded for a covered transaction.
Identification as a Repeat Finding – N/A
Recommendation – Policies and procedures should be modified to ensure the City verifies that vendors are not suspended, debarred, or otherwise excluded for a covered transaction.
Views of Responsible Officials and Planned Corrective Actions – We agree with the finding. See separate report for planned corrective actions.