Finding 2022-04: Special Test ? Reporting ? Significant Deficiency in Controls over Compliance and Noncompliance ALN #14.218? Community Development Block/Entitlement Grants Criteria ? Under the requirements of the Federal Funding Accountability and Transparency Act, 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). Condition/Context ? A total of $2,497,138 was passed through to sub recipients during the year and the subawards were not reported in the FSRS. There was a total of seven subrecipients that had expenses greater than $30,000 that were not reported in the FSRS. Dollar amount of Tested Transactions $2,497,138 Subaward not reported $2,497,138 Report not timely $2,497,138 Subaward amount incorrect 0 Subaward missing key elements. $2,497,138 Cause ? Grant Management was not aware of the reporting requirement. Effect ? Failure to report sub-award data could potentially constitute an event of noncompliance with the award contract, which may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Cost ? None. Recommendations ? Management should ensure that they have a mechanism for reporting subaward data in the FSRS. Views of Responsible Officials ? See Corrective Action Plan.
Finding 2022-03: Special Tests ? Required Certifications and HUD Approvals and Environmental Reviews ? Significant Deficiency in Controls over Compliance and Noncompliance ALN #14.218? Community Development Block/Entitlement Grants (CDBG) Criteria ? CDBG funds (and local funds to be reimbursed with CDBG funds) cannot be obligated or expended before receipt of Department of Housing and Urban Development (HUD) approval of a Request for Release of Funds (RROF) and environmental certification, except for exempt activities under 24 CFR section 58.34 Projects must have an environmental review unless they meet criteria specified in the regulations that would exempt or exclude them from Request for Release of Funds (RROF) and environmental certification requirements (24 CFR sections 58.1, 58.22, 58.34, 58.35, and 570.604). Accordingly, the grantee should maintain documentation if any determination not to make an environmental review was made consistent with the criteria contained in 24 CFR sections 58.34 and 58.35(b). Condition/Context ? Per discussion with grant management, the documentation substantiating the exempt status of the environmental reviews were completed, however the documentation was lost due to unforeseen circumstances and was unavailable for observation during the audit process. Per our understanding of the projects and discussions with management, the projects are effectively exempt based on 24 CFR 58.34. However, the exempt status of the projects could not be verified because the documentation was not properly retained by the County. Cause ? During the year the grant management team had to relocate, and the physical documentation got misplaced during the process. The grant manager handling the documentation of the environmental reviews experienced technology issues which further caused a loss of information. Effect ? Failure to retain or backup documentation could potentially constitute an event of noncompliance with the award contract, which may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Cost ? None. Recommendations ? Management should ensure that they have a mechanism for storing and backing up documentation pertaining to environmental review. Views of Responsible Officials ? See Corrective Action Plan
Finding 2022-04: Special Test ? Reporting ? Significant Deficiency in Controls over Compliance and Noncompliance ALN #14.218? Community Development Block/Entitlement Grants Criteria ? Under the requirements of the Federal Funding Accountability and Transparency Act, 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). Condition/Context ? A total of $2,497,138 was passed through to sub recipients during the year and the subawards were not reported in the FSRS. There was a total of seven subrecipients that had expenses greater than $30,000 that were not reported in the FSRS. Dollar amount of Tested Transactions $2,497,138 Subaward not reported $2,497,138 Report not timely $2,497,138 Subaward amount incorrect 0 Subaward missing key elements. $2,497,138 Cause ? Grant Management was not aware of the reporting requirement. Effect ? Failure to report sub-award data could potentially constitute an event of noncompliance with the award contract, which may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Cost ? None. Recommendations ? Management should ensure that they have a mechanism for reporting subaward data in the FSRS. Views of Responsible Officials ? See Corrective Action Plan.
Finding 2022-03: Special Tests ? Required Certifications and HUD Approvals and Environmental Reviews ? Significant Deficiency in Controls over Compliance and Noncompliance ALN #14.218? Community Development Block/Entitlement Grants (CDBG) Criteria ? CDBG funds (and local funds to be reimbursed with CDBG funds) cannot be obligated or expended before receipt of Department of Housing and Urban Development (HUD) approval of a Request for Release of Funds (RROF) and environmental certification, except for exempt activities under 24 CFR section 58.34 Projects must have an environmental review unless they meet criteria specified in the regulations that would exempt or exclude them from Request for Release of Funds (RROF) and environmental certification requirements (24 CFR sections 58.1, 58.22, 58.34, 58.35, and 570.604). Accordingly, the grantee should maintain documentation if any determination not to make an environmental review was made consistent with the criteria contained in 24 CFR sections 58.34 and 58.35(b). Condition/Context ? Per discussion with grant management, the documentation substantiating the exempt status of the environmental reviews were completed, however the documentation was lost due to unforeseen circumstances and was unavailable for observation during the audit process. Per our understanding of the projects and discussions with management, the projects are effectively exempt based on 24 CFR 58.34. However, the exempt status of the projects could not be verified because the documentation was not properly retained by the County. Cause ? During the year the grant management team had to relocate, and the physical documentation got misplaced during the process. The grant manager handling the documentation of the environmental reviews experienced technology issues which further caused a loss of information. Effect ? Failure to retain or backup documentation could potentially constitute an event of noncompliance with the award contract, which may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Cost ? None. Recommendations ? Management should ensure that they have a mechanism for storing and backing up documentation pertaining to environmental review. Views of Responsible Officials ? See Corrective Action Plan
Finding 2022-02: Control and Compliance Finding ? Significant Deficiency Coronavirus State and Local Fiscal Recovery Funds ? Reporting ALN #21.027 ? Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Criteria ? As noted in the 2022 OMB Compliance Supplement and the grant agreements, Quarterly Project and Expenditure Reports are required to be submitted to the Treasury?s Office of Inspector General by grantees to report financial data, projects funded, expenditures, and contracts/subawards over $50,000. Condition/Context ? During the testing of the reporting compliance requirement for the CSLFRF program, we tested all four Project and Expenditure reports that were submitted to the grantor in fiscal year 2022 (one initial report and three quarterly reports). We noted that within each quarterly report, subsequent to the initial report submitted for the March 2021 ? December 2021 reporting period, the cumulative expenditures and obligations from the prior period report plus the current period expenditures and obligations reported did not mathematically agree to the cumulative expenditures and obligations on the report for that period. In addition to the mathematical differences found, the reported cumulative obligations following the initial report (Quarters 2, 3, and 4) did not agree to underlying support. Cause ? The grants administrators did not accurately report cumulative expenditures and obligations that occurred over the cumulation of the grant. There also was a lack of review by the grants audit to ensure accurate reporting. Effect ? Inaccurate reporting of expenditures and obligations of each project from report to report was communicated to the grantor. Inappropriate representation of expenditures and obligations on reporting may result in the early termination of the grant award or cessation of future funding. Questioned Cost ? None. Recommendations ? Management should ensure that they have a mechanism for tracking the reporting requirements and activity occurring in each reporting period. Management should also ensure all submitted reports are properly reviewed for all reporting requirements. Views of Responsible Officials ? See Corrective Action Plan.
Finding 2022-02: Control and Compliance Finding ? Significant Deficiency Coronavirus State and Local Fiscal Recovery Funds ? Reporting ALN #21.027 ? Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Criteria ? As noted in the 2022 OMB Compliance Supplement and the grant agreements, Quarterly Project and Expenditure Reports are required to be submitted to the Treasury?s Office of Inspector General by grantees to report financial data, projects funded, expenditures, and contracts/subawards over $50,000. Condition/Context ? During the testing of the reporting compliance requirement for the CSLFRF program, we tested all four Project and Expenditure reports that were submitted to the grantor in fiscal year 2022 (one initial report and three quarterly reports). We noted that within each quarterly report, subsequent to the initial report submitted for the March 2021 ? December 2021 reporting period, the cumulative expenditures and obligations from the prior period report plus the current period expenditures and obligations reported did not mathematically agree to the cumulative expenditures and obligations on the report for that period. In addition to the mathematical differences found, the reported cumulative obligations following the initial report (Quarters 2, 3, and 4) did not agree to underlying support. Cause ? The grants administrators did not accurately report cumulative expenditures and obligations that occurred over the cumulation of the grant. There also was a lack of review by the grants audit to ensure accurate reporting. Effect ? Inaccurate reporting of expenditures and obligations of each project from report to report was communicated to the grantor. Inappropriate representation of expenditures and obligations on reporting may result in the early termination of the grant award or cessation of future funding. Questioned Cost ? None. Recommendations ? Management should ensure that they have a mechanism for tracking the reporting requirements and activity occurring in each reporting period. Management should also ensure all submitted reports are properly reviewed for all reporting requirements. Views of Responsible Officials ? See Corrective Action Plan.
Finding 2022-04: Special Test ? Reporting ? Significant Deficiency in Controls over Compliance and Noncompliance ALN #14.218? Community Development Block/Entitlement Grants Criteria ? Under the requirements of the Federal Funding Accountability and Transparency Act, 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). Condition/Context ? A total of $2,497,138 was passed through to sub recipients during the year and the subawards were not reported in the FSRS. There was a total of seven subrecipients that had expenses greater than $30,000 that were not reported in the FSRS. Dollar amount of Tested Transactions $2,497,138 Subaward not reported $2,497,138 Report not timely $2,497,138 Subaward amount incorrect 0 Subaward missing key elements. $2,497,138 Cause ? Grant Management was not aware of the reporting requirement. Effect ? Failure to report sub-award data could potentially constitute an event of noncompliance with the award contract, which may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Cost ? None. Recommendations ? Management should ensure that they have a mechanism for reporting subaward data in the FSRS. Views of Responsible Officials ? See Corrective Action Plan.
Finding 2022-03: Special Tests ? Required Certifications and HUD Approvals and Environmental Reviews ? Significant Deficiency in Controls over Compliance and Noncompliance ALN #14.218? Community Development Block/Entitlement Grants (CDBG) Criteria ? CDBG funds (and local funds to be reimbursed with CDBG funds) cannot be obligated or expended before receipt of Department of Housing and Urban Development (HUD) approval of a Request for Release of Funds (RROF) and environmental certification, except for exempt activities under 24 CFR section 58.34 Projects must have an environmental review unless they meet criteria specified in the regulations that would exempt or exclude them from Request for Release of Funds (RROF) and environmental certification requirements (24 CFR sections 58.1, 58.22, 58.34, 58.35, and 570.604). Accordingly, the grantee should maintain documentation if any determination not to make an environmental review was made consistent with the criteria contained in 24 CFR sections 58.34 and 58.35(b). Condition/Context ? Per discussion with grant management, the documentation substantiating the exempt status of the environmental reviews were completed, however the documentation was lost due to unforeseen circumstances and was unavailable for observation during the audit process. Per our understanding of the projects and discussions with management, the projects are effectively exempt based on 24 CFR 58.34. However, the exempt status of the projects could not be verified because the documentation was not properly retained by the County. Cause ? During the year the grant management team had to relocate, and the physical documentation got misplaced during the process. The grant manager handling the documentation of the environmental reviews experienced technology issues which further caused a loss of information. Effect ? Failure to retain or backup documentation could potentially constitute an event of noncompliance with the award contract, which may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Cost ? None. Recommendations ? Management should ensure that they have a mechanism for storing and backing up documentation pertaining to environmental review. Views of Responsible Officials ? See Corrective Action Plan
Finding 2022-04: Special Test ? Reporting ? Significant Deficiency in Controls over Compliance and Noncompliance ALN #14.218? Community Development Block/Entitlement Grants Criteria ? Under the requirements of the Federal Funding Accountability and Transparency Act, 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). Condition/Context ? A total of $2,497,138 was passed through to sub recipients during the year and the subawards were not reported in the FSRS. There was a total of seven subrecipients that had expenses greater than $30,000 that were not reported in the FSRS. Dollar amount of Tested Transactions $2,497,138 Subaward not reported $2,497,138 Report not timely $2,497,138 Subaward amount incorrect 0 Subaward missing key elements. $2,497,138 Cause ? Grant Management was not aware of the reporting requirement. Effect ? Failure to report sub-award data could potentially constitute an event of noncompliance with the award contract, which may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Cost ? None. Recommendations ? Management should ensure that they have a mechanism for reporting subaward data in the FSRS. Views of Responsible Officials ? See Corrective Action Plan.
Finding 2022-03: Special Tests ? Required Certifications and HUD Approvals and Environmental Reviews ? Significant Deficiency in Controls over Compliance and Noncompliance ALN #14.218? Community Development Block/Entitlement Grants (CDBG) Criteria ? CDBG funds (and local funds to be reimbursed with CDBG funds) cannot be obligated or expended before receipt of Department of Housing and Urban Development (HUD) approval of a Request for Release of Funds (RROF) and environmental certification, except for exempt activities under 24 CFR section 58.34 Projects must have an environmental review unless they meet criteria specified in the regulations that would exempt or exclude them from Request for Release of Funds (RROF) and environmental certification requirements (24 CFR sections 58.1, 58.22, 58.34, 58.35, and 570.604). Accordingly, the grantee should maintain documentation if any determination not to make an environmental review was made consistent with the criteria contained in 24 CFR sections 58.34 and 58.35(b). Condition/Context ? Per discussion with grant management, the documentation substantiating the exempt status of the environmental reviews were completed, however the documentation was lost due to unforeseen circumstances and was unavailable for observation during the audit process. Per our understanding of the projects and discussions with management, the projects are effectively exempt based on 24 CFR 58.34. However, the exempt status of the projects could not be verified because the documentation was not properly retained by the County. Cause ? During the year the grant management team had to relocate, and the physical documentation got misplaced during the process. The grant manager handling the documentation of the environmental reviews experienced technology issues which further caused a loss of information. Effect ? Failure to retain or backup documentation could potentially constitute an event of noncompliance with the award contract, which may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. Questioned Cost ? None. Recommendations ? Management should ensure that they have a mechanism for storing and backing up documentation pertaining to environmental review. Views of Responsible Officials ? See Corrective Action Plan
Finding 2022-02: Control and Compliance Finding ? Significant Deficiency Coronavirus State and Local Fiscal Recovery Funds ? Reporting ALN #21.027 ? Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Criteria ? As noted in the 2022 OMB Compliance Supplement and the grant agreements, Quarterly Project and Expenditure Reports are required to be submitted to the Treasury?s Office of Inspector General by grantees to report financial data, projects funded, expenditures, and contracts/subawards over $50,000. Condition/Context ? During the testing of the reporting compliance requirement for the CSLFRF program, we tested all four Project and Expenditure reports that were submitted to the grantor in fiscal year 2022 (one initial report and three quarterly reports). We noted that within each quarterly report, subsequent to the initial report submitted for the March 2021 ? December 2021 reporting period, the cumulative expenditures and obligations from the prior period report plus the current period expenditures and obligations reported did not mathematically agree to the cumulative expenditures and obligations on the report for that period. In addition to the mathematical differences found, the reported cumulative obligations following the initial report (Quarters 2, 3, and 4) did not agree to underlying support. Cause ? The grants administrators did not accurately report cumulative expenditures and obligations that occurred over the cumulation of the grant. There also was a lack of review by the grants audit to ensure accurate reporting. Effect ? Inaccurate reporting of expenditures and obligations of each project from report to report was communicated to the grantor. Inappropriate representation of expenditures and obligations on reporting may result in the early termination of the grant award or cessation of future funding. Questioned Cost ? None. Recommendations ? Management should ensure that they have a mechanism for tracking the reporting requirements and activity occurring in each reporting period. Management should also ensure all submitted reports are properly reviewed for all reporting requirements. Views of Responsible Officials ? See Corrective Action Plan.
Finding 2022-02: Control and Compliance Finding ? Significant Deficiency Coronavirus State and Local Fiscal Recovery Funds ? Reporting ALN #21.027 ? Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Criteria ? As noted in the 2022 OMB Compliance Supplement and the grant agreements, Quarterly Project and Expenditure Reports are required to be submitted to the Treasury?s Office of Inspector General by grantees to report financial data, projects funded, expenditures, and contracts/subawards over $50,000. Condition/Context ? During the testing of the reporting compliance requirement for the CSLFRF program, we tested all four Project and Expenditure reports that were submitted to the grantor in fiscal year 2022 (one initial report and three quarterly reports). We noted that within each quarterly report, subsequent to the initial report submitted for the March 2021 ? December 2021 reporting period, the cumulative expenditures and obligations from the prior period report plus the current period expenditures and obligations reported did not mathematically agree to the cumulative expenditures and obligations on the report for that period. In addition to the mathematical differences found, the reported cumulative obligations following the initial report (Quarters 2, 3, and 4) did not agree to underlying support. Cause ? The grants administrators did not accurately report cumulative expenditures and obligations that occurred over the cumulation of the grant. There also was a lack of review by the grants audit to ensure accurate reporting. Effect ? Inaccurate reporting of expenditures and obligations of each project from report to report was communicated to the grantor. Inappropriate representation of expenditures and obligations on reporting may result in the early termination of the grant award or cessation of future funding. Questioned Cost ? None. Recommendations ? Management should ensure that they have a mechanism for tracking the reporting requirements and activity occurring in each reporting period. Management should also ensure all submitted reports are properly reviewed for all reporting requirements. Views of Responsible Officials ? See Corrective Action Plan.