Assistance Listing, Federal Agency, and Program Name - 15.507, WaterSMART Sustaining and Manage America’s Resources for Tomorrow
Federal Award Identification Number and Year - R22AP00523-00
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), a 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. 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 - Controls in place were not adequate to ensure expenses were reported in the proper categories on the performance reports.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - During reporting testing, we noted no expenses were reported in the federal expenses line item of the two reports tested.
Cause and Effect - While the City did have controls in place around reporting and allowability of expenses, they were not sufficient to ensure expenses were properly reported on the correct lines As a result, reports were not in compliance.
Recommendation - We recommend the City ensure the effectiveness of controls to ensure expenditures get reported properly.
Views of Responsible Officials and Corrective Action Plan - The City hired a full-time Grants Manager in February 2024 to establish procedures to track grants that are awarded and expended by the City. New procedures will be developed to ensure that financial and performance reports for grants will be reviewed by the Grants Manager prior to submission of the reports to the awarding entities. Documentation of this review will be retained with the grant documents.
Assistance Listing, Federal Agency, and Program Name - 21.027, U.S. Department of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year - 2023; 20-HA4-XC-03002, SLFRP0126
Pass-through Entity - Colorado Department of Local Affairs
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 180.300, before entering into a covered transaction with another person, grant recipients must verify that the person with whom they intend to do business is not excluded or disqualified. This is done by (a) checking SAM exclusions, (b) collecting a certification from that person, or (c) adding a clause or condition to the covered transaction with that person.
Condition - The City did not retain evidence that they performed the suspension and debarment check prior to entering into the contract.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - One contract was selected for testing and it was noted that the City did not retain evidence that they performed the suspension and debarment check prior to entering into the contract. The City performed the check after the fact and noted that none of the contractors were suspended or debarred, therefore creating no questionned costs.
Cause and Effect - Controls in place did not ensure the City verified contractors paid were not excluded or disqualified prior to entering into transactions with the contractors.
Recommendation - We recommend the City establish a procedure to check for whether a contractor is suspended or debarred before entering into a contract and retain evidence of the search.
Views of Responsible Officials and Planned Corrective Actions - Procedures will be enhanced to ensure prior to entering into an agreement with an outside entity using federal funds, the City will perform the suspension and debarment check. Documentation of this review will be retained with the grant documents. In addition, the City will research grant management software options to further enhance grant monitoring.
Assistance Listing, Federal Agency, and Program Name - 21.027, U.S. Department of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year - 2023; 20-HA4-XC-03002, SLFRP0126
Pass-through Entity - Colorado Department of Local Affairs
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 180.300, before entering into a covered transaction with another person, grant recipients must verify that the person with whom they intend to do business is not excluded or disqualified. This is done by (a) checking SAM exclusions, (b) collecting a certification from that person, or (c) adding a clause or condition to the covered transaction with that person.
Condition - The City did not retain evidence that they performed the suspension and debarment check prior to entering into the contract.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - One contract was selected for testing and it was noted that the City did not retain evidence that they performed the suspension and debarment check prior to entering into the contract. The City performed the check after the fact and noted that none of the contractors were suspended or debarred, therefore creating no questionned costs.
Cause and Effect - Controls in place did not ensure the City verified contractors paid were not excluded or disqualified prior to entering into transactions with the contractors.
Recommendation - We recommend the City establish a procedure to check for whether a contractor is suspended or debarred before entering into a contract and retain evidence of the search.
Views of Responsible Officials and Planned Corrective Actions - Procedures will be enhanced to ensure prior to entering into an agreement with an outside entity using federal funds, the City will perform the suspension and debarment check. Documentation of this review will be retained with the grant documents. In addition, the City will research grant management software options to further enhance grant monitoring.
Assistance Listing, Federal Agency, and Program Name - 21.027, U.S. Department of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year - 2023; 20-HA4-XC-03002, SLFRP0126
Pass-through Entity - Colorado Department of Local Affairs
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 180.300, before entering into a covered transaction with another person, grant recipients must verify that the person with whom they intend to do business is not excluded or disqualified. This is done by (a) checking SAM exclusions, (b) collecting a certification from that person, or (c) adding a clause or condition to the covered transaction with that person.
Condition - The City did not retain evidence that they performed the suspension and debarment check prior to entering into the contract.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - One contract was selected for testing and it was noted that the City did not retain evidence that they performed the suspension and debarment check prior to entering into the contract. The City performed the check after the fact and noted that none of the contractors were suspended or debarred, therefore creating no questionned costs.
Cause and Effect - Controls in place did not ensure the City verified contractors paid were not excluded or disqualified prior to entering into transactions with the contractors.
Recommendation - We recommend the City establish a procedure to check for whether a contractor is suspended or debarred before entering into a contract and retain evidence of the search.
Views of Responsible Officials and Planned Corrective Actions - Procedures will be enhanced to ensure prior to entering into an agreement with an outside entity using federal funds, the City will perform the suspension and debarment check. Documentation of this review will be retained with the grant documents. In addition, the City will research grant management software options to further enhance grant monitoring.
Assistance Listing, Federal Agency, and Program Name - 21.027, U.S. Department of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year - 2023; 20-HA4-XC-03002, SLFRP0126
Pass-through Entity - Colorado Department of Transportation; Colorado Department of Local Affairs
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), a non-federal entity mus 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. 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 - There was no evidence that reports were reviewed for completeness and accuracy prior to submission.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - During reporting testing, of the 3 reports selected for testing, we noted that none of them showed evidence of review for completeness and accuracy prior to submission.
Cause and Effect - The City did not have controls in place around reviews of reporting. As a result, reports were not reviewed prior to submission.
Recommendation - We recommend the City implement controls to ensure a review of all reports are performed by someone other than the preparer, prior to submission.
Views of Responsible Officials and Planned Corrective Actions - The City hired a full-time Grants Manager in February 2024 to establish procedures to track grants that are awarded and expended by the City. New procedures will be developed to ensure that financial and performance reports for grants will be reviewed and approved by the Grants Manager prior to submission of the reports to the awarding entities. Documentation of this review will be retained with the grant documents.
Assistance Listing, Federal Agency, and Program Name - 21.027, U.S. Department of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year - 2023; 20-HA4-XC-03002, SLFRP0126
Pass-through Entity - Colorado Department of Transportation; Colorado Department of Local Affairs
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), a non-federal entity mus 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. 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 - There was no evidence that reports were reviewed for completeness and accuracy prior to submission.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - During reporting testing, of the 3 reports selected for testing, we noted that none of them showed evidence of review for completeness and accuracy prior to submission.
Cause and Effect - The City did not have controls in place around reviews of reporting. As a result, reports were not reviewed prior to submission.
Recommendation - We recommend the City implement controls to ensure a review of all reports are performed by someone other than the preparer, prior to submission.
Views of Responsible Officials and Planned Corrective Actions - The City hired a full-time Grants Manager in February 2024 to establish procedures to track grants that are awarded and expended by the City. New procedures will be developed to ensure that financial and performance reports for grants will be reviewed and approved by the Grants Manager prior to submission of the reports to the awarding entities. Documentation of this review will be retained with the grant documents.
Assistance Listing, Federal Agency, and Program Name - 21.027, U.S. Department of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year - 2023; 20-HA4-XC-03002, SLFRP0126
Pass-through Entity - Colorado Department of Transportation; Colorado Department of Local Affairs
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), a non-federal entity mus 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. 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 - There was no evidence that reports were reviewed for completeness and accuracy prior to submission.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - During reporting testing, of the 3 reports selected for testing, we noted that none of them showed evidence of review for completeness and accuracy prior to submission.
Cause and Effect - The City did not have controls in place around reviews of reporting. As a result, reports were not reviewed prior to submission.
Recommendation - We recommend the City implement controls to ensure a review of all reports are performed by someone other than the preparer, prior to submission.
Views of Responsible Officials and Planned Corrective Actions - The City hired a full-time Grants Manager in February 2024 to establish procedures to track grants that are awarded and expended by the City. New procedures will be developed to ensure that financial and performance reports for grants will be reviewed and approved by the Grants Manager prior to submission of the reports to the awarding entities. Documentation of this review will be retained with the grant documents.
Assistance Listing, Federal Agency, and Program Name - 15.507, WaterSMART Sustaining and Manage America’s Resources for Tomorrow
Federal Award Identification Number and Year - R22AP00523-00
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), a 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. 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 - Controls in place were not adequate to ensure expenses were reported in the proper categories on the performance reports.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - During reporting testing, we noted no expenses were reported in the federal expenses line item of the two reports tested.
Cause and Effect - While the City did have controls in place around reporting and allowability of expenses, they were not sufficient to ensure expenses were properly reported on the correct lines As a result, reports were not in compliance.
Recommendation - We recommend the City ensure the effectiveness of controls to ensure expenditures get reported properly.
Views of Responsible Officials and Corrective Action Plan - The City hired a full-time Grants Manager in February 2024 to establish procedures to track grants that are awarded and expended by the City. New procedures will be developed to ensure that financial and performance reports for grants will be reviewed by the Grants Manager prior to submission of the reports to the awarding entities. Documentation of this review will be retained with the grant documents.
Assistance Listing, Federal Agency, and Program Name - 21.027, U.S. Department of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year - 2023; 20-HA4-XC-03002, SLFRP0126
Pass-through Entity - Colorado Department of Local Affairs
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 180.300, before entering into a covered transaction with another person, grant recipients must verify that the person with whom they intend to do business is not excluded or disqualified. This is done by (a) checking SAM exclusions, (b) collecting a certification from that person, or (c) adding a clause or condition to the covered transaction with that person.
Condition - The City did not retain evidence that they performed the suspension and debarment check prior to entering into the contract.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - One contract was selected for testing and it was noted that the City did not retain evidence that they performed the suspension and debarment check prior to entering into the contract. The City performed the check after the fact and noted that none of the contractors were suspended or debarred, therefore creating no questionned costs.
Cause and Effect - Controls in place did not ensure the City verified contractors paid were not excluded or disqualified prior to entering into transactions with the contractors.
Recommendation - We recommend the City establish a procedure to check for whether a contractor is suspended or debarred before entering into a contract and retain evidence of the search.
Views of Responsible Officials and Planned Corrective Actions - Procedures will be enhanced to ensure prior to entering into an agreement with an outside entity using federal funds, the City will perform the suspension and debarment check. Documentation of this review will be retained with the grant documents. In addition, the City will research grant management software options to further enhance grant monitoring.
Assistance Listing, Federal Agency, and Program Name - 21.027, U.S. Department of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year - 2023; 20-HA4-XC-03002, SLFRP0126
Pass-through Entity - Colorado Department of Local Affairs
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 180.300, before entering into a covered transaction with another person, grant recipients must verify that the person with whom they intend to do business is not excluded or disqualified. This is done by (a) checking SAM exclusions, (b) collecting a certification from that person, or (c) adding a clause or condition to the covered transaction with that person.
Condition - The City did not retain evidence that they performed the suspension and debarment check prior to entering into the contract.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - One contract was selected for testing and it was noted that the City did not retain evidence that they performed the suspension and debarment check prior to entering into the contract. The City performed the check after the fact and noted that none of the contractors were suspended or debarred, therefore creating no questionned costs.
Cause and Effect - Controls in place did not ensure the City verified contractors paid were not excluded or disqualified prior to entering into transactions with the contractors.
Recommendation - We recommend the City establish a procedure to check for whether a contractor is suspended or debarred before entering into a contract and retain evidence of the search.
Views of Responsible Officials and Planned Corrective Actions - Procedures will be enhanced to ensure prior to entering into an agreement with an outside entity using federal funds, the City will perform the suspension and debarment check. Documentation of this review will be retained with the grant documents. In addition, the City will research grant management software options to further enhance grant monitoring.
Assistance Listing, Federal Agency, and Program Name - 21.027, U.S. Department of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year - 2023; 20-HA4-XC-03002, SLFRP0126
Pass-through Entity - Colorado Department of Local Affairs
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Per 2 CFR 180.300, before entering into a covered transaction with another person, grant recipients must verify that the person with whom they intend to do business is not excluded or disqualified. This is done by (a) checking SAM exclusions, (b) collecting a certification from that person, or (c) adding a clause or condition to the covered transaction with that person.
Condition - The City did not retain evidence that they performed the suspension and debarment check prior to entering into the contract.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - One contract was selected for testing and it was noted that the City did not retain evidence that they performed the suspension and debarment check prior to entering into the contract. The City performed the check after the fact and noted that none of the contractors were suspended or debarred, therefore creating no questionned costs.
Cause and Effect - Controls in place did not ensure the City verified contractors paid were not excluded or disqualified prior to entering into transactions with the contractors.
Recommendation - We recommend the City establish a procedure to check for whether a contractor is suspended or debarred before entering into a contract and retain evidence of the search.
Views of Responsible Officials and Planned Corrective Actions - Procedures will be enhanced to ensure prior to entering into an agreement with an outside entity using federal funds, the City will perform the suspension and debarment check. Documentation of this review will be retained with the grant documents. In addition, the City will research grant management software options to further enhance grant monitoring.
Assistance Listing, Federal Agency, and Program Name - 21.027, U.S. Department of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year - 2023; 20-HA4-XC-03002, SLFRP0126
Pass-through Entity - Colorado Department of Transportation; Colorado Department of Local Affairs
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), a non-federal entity mus 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. 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 - There was no evidence that reports were reviewed for completeness and accuracy prior to submission.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - During reporting testing, of the 3 reports selected for testing, we noted that none of them showed evidence of review for completeness and accuracy prior to submission.
Cause and Effect - The City did not have controls in place around reviews of reporting. As a result, reports were not reviewed prior to submission.
Recommendation - We recommend the City implement controls to ensure a review of all reports are performed by someone other than the preparer, prior to submission.
Views of Responsible Officials and Planned Corrective Actions - The City hired a full-time Grants Manager in February 2024 to establish procedures to track grants that are awarded and expended by the City. New procedures will be developed to ensure that financial and performance reports for grants will be reviewed and approved by the Grants Manager prior to submission of the reports to the awarding entities. Documentation of this review will be retained with the grant documents.
Assistance Listing, Federal Agency, and Program Name - 21.027, U.S. Department of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year - 2023; 20-HA4-XC-03002, SLFRP0126
Pass-through Entity - Colorado Department of Transportation; Colorado Department of Local Affairs
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), a non-federal entity mus 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. 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 - There was no evidence that reports were reviewed for completeness and accuracy prior to submission.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - During reporting testing, of the 3 reports selected for testing, we noted that none of them showed evidence of review for completeness and accuracy prior to submission.
Cause and Effect - The City did not have controls in place around reviews of reporting. As a result, reports were not reviewed prior to submission.
Recommendation - We recommend the City implement controls to ensure a review of all reports are performed by someone other than the preparer, prior to submission.
Views of Responsible Officials and Planned Corrective Actions - The City hired a full-time Grants Manager in February 2024 to establish procedures to track grants that are awarded and expended by the City. New procedures will be developed to ensure that financial and performance reports for grants will be reviewed and approved by the Grants Manager prior to submission of the reports to the awarding entities. Documentation of this review will be retained with the grant documents.
Assistance Listing, Federal Agency, and Program Name - 21.027, U.S. Department of the Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year - 2023; 20-HA4-XC-03002, SLFRP0126
Pass-through Entity - Colorado Department of Transportation; Colorado Department of Local Affairs
Finding Type - Material weakness
Repeat Finding - No
Criteria - Per 2 CFR 200.303(a), a non-federal entity mus 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. 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 - There was no evidence that reports were reviewed for completeness and accuracy prior to submission.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - During reporting testing, of the 3 reports selected for testing, we noted that none of them showed evidence of review for completeness and accuracy prior to submission.
Cause and Effect - The City did not have controls in place around reviews of reporting. As a result, reports were not reviewed prior to submission.
Recommendation - We recommend the City implement controls to ensure a review of all reports are performed by someone other than the preparer, prior to submission.
Views of Responsible Officials and Planned Corrective Actions - The City hired a full-time Grants Manager in February 2024 to establish procedures to track grants that are awarded and expended by the City. New procedures will be developed to ensure that financial and performance reports for grants will be reviewed and approved by the Grants Manager prior to submission of the reports to the awarding entities. Documentation of this review will be retained with the grant documents.