2024-002 – Federal Funding Accountability and Transparency Act (FFATA) Reporting
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Reporting).
Federal program(s)
U.S. Department of Housing and Urban Development:
Community Development Block Grants/Entitlement Grants (ALN 14.218); Direct award; All project numbers.
Lead Hazard Reduction Grant Program (ALN 14.905); Direct award; All project numbers.
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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000.
Condition. The City did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance.
Cause. The City does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance.
Effect. The City did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients.
Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs were identified.
Recommendation. We recommend that the City review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward.
View of Responsible Officials. The City acknowledges reporting has lapsed in this system. New procedures have been put in place to ensure reporting occurs in a timely manner and there is oversight of the reporting throughout the year. These procedures include additional questions on internal documents regarding potential subrecipients, as well as monitoring Commission agendas, and regular reporting reminders.
Responsible Officials. Revenue Services Director
Estimated Completion Date. June 30, 2025
2024-002 – Federal Funding Accountability and Transparency Act (FFATA) Reporting
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Reporting).
Federal program(s)
U.S. Department of Housing and Urban Development:
Community Development Block Grants/Entitlement Grants (ALN 14.218); Direct award; All project numbers.
Lead Hazard Reduction Grant Program (ALN 14.905); Direct award; All project numbers.
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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000.
Condition. The City did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance.
Cause. The City does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance.
Effect. The City did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients.
Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs were identified.
Recommendation. We recommend that the City review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward.
View of Responsible Officials. The City acknowledges reporting has lapsed in this system. New procedures have been put in place to ensure reporting occurs in a timely manner and there is oversight of the reporting throughout the year. These procedures include additional questions on internal documents regarding potential subrecipients, as well as monitoring Commission agendas, and regular reporting reminders.
Responsible Officials. Revenue Services Director
Estimated Completion Date. June 30, 2025
2024-002 – Federal Funding Accountability and Transparency Act (FFATA) Reporting
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Reporting).
Federal program(s)
U.S. Department of Housing and Urban Development:
Community Development Block Grants/Entitlement Grants (ALN 14.218); Direct award; All project numbers.
Lead Hazard Reduction Grant Program (ALN 14.905); Direct award; All project numbers.
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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000.
Condition. The City did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance.
Cause. The City does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance.
Effect. The City did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients.
Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs were identified.
Recommendation. We recommend that the City review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward.
View of Responsible Officials. The City acknowledges reporting has lapsed in this system. New procedures have been put in place to ensure reporting occurs in a timely manner and there is oversight of the reporting throughout the year. These procedures include additional questions on internal documents regarding potential subrecipients, as well as monitoring Commission agendas, and regular reporting reminders.
Responsible Officials. Revenue Services Director
Estimated Completion Date. June 30, 2025
2024-002 – Federal Funding Accountability and Transparency Act (FFATA) Reporting
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Reporting).
Federal program(s)
U.S. Department of Housing and Urban Development:
Community Development Block Grants/Entitlement Grants (ALN 14.218); Direct award; All project numbers.
Lead Hazard Reduction Grant Program (ALN 14.905); Direct award; All project numbers.
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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000.
Condition. The City did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance.
Cause. The City does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance.
Effect. The City did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients.
Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs were identified.
Recommendation. We recommend that the City review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward.
View of Responsible Officials. The City acknowledges reporting has lapsed in this system. New procedures have been put in place to ensure reporting occurs in a timely manner and there is oversight of the reporting throughout the year. These procedures include additional questions on internal documents regarding potential subrecipients, as well as monitoring Commission agendas, and regular reporting reminders.
Responsible Officials. Revenue Services Director
Estimated Completion Date. June 30, 2025
2024-002 – Federal Funding Accountability and Transparency Act (FFATA) Reporting
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Reporting).
Federal program(s)
U.S. Department of Housing and Urban Development:
Community Development Block Grants/Entitlement Grants (ALN 14.218); Direct award; All project numbers.
Lead Hazard Reduction Grant Program (ALN 14.905); Direct award; All project numbers.
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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000.
Condition. The City did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance.
Cause. The City does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance.
Effect. The City did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients.
Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs were identified.
Recommendation. We recommend that the City review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward.
View of Responsible Officials. The City acknowledges reporting has lapsed in this system. New procedures have been put in place to ensure reporting occurs in a timely manner and there is oversight of the reporting throughout the year. These procedures include additional questions on internal documents regarding potential subrecipients, as well as monitoring Commission agendas, and regular reporting reminders.
Responsible Officials. Revenue Services Director
Estimated Completion Date. June 30, 2025
2024-003 – Timely Reporting
Federal program(s)
U.S. Department of Housing and Urban Development -
Lead Hazard Reduction Grant Program (ALN 14.905); Direct award; All project numbers.
Criteria. Recipients of federal awards are required to report periodically on financial information, as specified by the 2 CFR 200 Compliance Supplement or grant agreement. Reported information should be supported by the entity’s accounting records and subjected to an independent review and approval prior to submission in order to detect and correct any errors or omissions. Quarterly SF-425 reports are due no later than January 30, April 30, July 31, and October 31 for the preceding quarter. Additionally, HUD requires recipients that provide HUD-program benefits to individuals or families to report data on race, ethnicity and other data annually by using form HUD-27061, which must be submitted annually by January 10.
Condition. During our audit procedures over the City's reporting process, we noted that the City did not submit the quarterly SF-425 reports for fiscal year by the deadlines outlined in the grant agreements. Additionally, it was noted that the City did not complete and submit the required race and ethnic data for fiscal year 2024 using form HUD-27061.
Cause. This condition was caused by the lack of understanding by program staff of the specific requirements of reporting on forms SF-425 and HUD-27061.
Effect. As a result of this condition, the City did not comply fully with the reporting requirements under this federal award. In addition, the City was exposed to an increased risk that the reports filed could contain errors and not be detected and corrected on a timely basis.
Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs were identified.
Recommendation. We recommend that the City establish procedures to ensure that the HUD-27061 form is completed. We also recommend that all required reports are filed by their deadlines.
View of Responsible Officials. The City acknowledges the SF-425 reports for the Lead Hazard Reduction Grant Program were not timely submitted. Finance and Community Development will work together to strengthen financial reporting so that it is timely moving forward. Staff working on this grant are new to their positions since the last time the program was audited, and are committed to reviewing policies and procedures to make sure reporting is completed appropriately. Community Development will work with HUD to clarify the use of form HUD-27061.
Responsible Officials. Revenue Services Director and Community Services Director
Estimated Completion Date. June 30, 2025
2024-004 – Inaccurate Reporting/Lack of Independent Review and Approval of Reporting
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Reporting).
Federal program(s)
U.S. Department of Housing and Urban Development -
Community Development Block Grants/Entitlement Grants (ALN 14.218); Direct award; All project numbers.
Criteria. Recipients of federal awards are required to report periodically on financial information, as specified by the 2 CFR 200 Compliance Supplement or grant agreement. Reported information should be supported by the entity’s accounting records and subjected to an independent review and approval prior to submission in order to detect and correct any errors or omissions. Additionally, the PR-26 financial summary reports are submitted as part of the Consolidated Annual Performance Evaluation Report (CAPER). This report should include all expenditures for the program year, including accrued expenditures.
Condition. During our audit procedures over the City's annual PR-26 reports and the annual CAPER, we noted that none of the reports were subject to an independent review and approval prior to submission in order to detect and correct potential errors or omissions. We also noted that the CAPER was submitted as required, but contained financial data that did not agree to the City's underlying accounting records for the reporting period as required. The City's annual PR-26 report did not agree to the annual CAPER by approximately $435,000 and needed to be resubmitted to HUD.
Cause. This condition appears to have been caused by a lack of complete knowledge of applicable federal compliance requirements and employee turnover in the economic development department.
Effect. As a result of this condition, the City did not fully comply with the requirements of the grant and filed reports that contained financial errors.
Questioned Costs. No costs have been questioned as a result of this finding as the reports did not serve as a basis for cost-reimbursement.
Recommendation. We recommend that reports required to be submitted to the oversight agency that contain financial information be reviewed and approved by the finance department to ensure accuracy of the financial information.
View of Responsible Officials. The City acknowledges the issues noted with reporting in the Community Development Block Grant Program. Finance and Community Development will work together to strengthen programmatic and financial reporting so that it is both timely and accurate. Staff working on this grant are new to their positions since the last time the program was audited, and are committed to reviewing policies and procedures to make sure reporting is completed appropriately.
Responsible Officials. Revenue Services Director and Community Services Director
Estimated Completion Date. June 30, 2025
2024-004 – Inaccurate Reporting/Lack of Independent Review and Approval of Reporting
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Reporting).
Federal program(s)
U.S. Department of Housing and Urban Development -
Community Development Block Grants/Entitlement Grants (ALN 14.218); Direct award; All project numbers.
Criteria. Recipients of federal awards are required to report periodically on financial information, as specified by the 2 CFR 200 Compliance Supplement or grant agreement. Reported information should be supported by the entity’s accounting records and subjected to an independent review and approval prior to submission in order to detect and correct any errors or omissions. Additionally, the PR-26 financial summary reports are submitted as part of the Consolidated Annual Performance Evaluation Report (CAPER). This report should include all expenditures for the program year, including accrued expenditures.
Condition. During our audit procedures over the City's annual PR-26 reports and the annual CAPER, we noted that none of the reports were subject to an independent review and approval prior to submission in order to detect and correct potential errors or omissions. We also noted that the CAPER was submitted as required, but contained financial data that did not agree to the City's underlying accounting records for the reporting period as required. The City's annual PR-26 report did not agree to the annual CAPER by approximately $435,000 and needed to be resubmitted to HUD.
Cause. This condition appears to have been caused by a lack of complete knowledge of applicable federal compliance requirements and employee turnover in the economic development department.
Effect. As a result of this condition, the City did not fully comply with the requirements of the grant and filed reports that contained financial errors.
Questioned Costs. No costs have been questioned as a result of this finding as the reports did not serve as a basis for cost-reimbursement.
Recommendation. We recommend that reports required to be submitted to the oversight agency that contain financial information be reviewed and approved by the finance department to ensure accuracy of the financial information.
View of Responsible Officials. The City acknowledges the issues noted with reporting in the Community Development Block Grant Program. Finance and Community Development will work together to strengthen programmatic and financial reporting so that it is both timely and accurate. Staff working on this grant are new to their positions since the last time the program was audited, and are committed to reviewing policies and procedures to make sure reporting is completed appropriately.
Responsible Officials. Revenue Services Director and Community Services Director
Estimated Completion Date. June 30, 2025
2024-004 – Inaccurate Reporting/Lack of Independent Review and Approval of Reporting
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Reporting).
Federal program(s)
U.S. Department of Housing and Urban Development -
Community Development Block Grants/Entitlement Grants (ALN 14.218); Direct award; All project numbers.
Criteria. Recipients of federal awards are required to report periodically on financial information, as specified by the 2 CFR 200 Compliance Supplement or grant agreement. Reported information should be supported by the entity’s accounting records and subjected to an independent review and approval prior to submission in order to detect and correct any errors or omissions. Additionally, the PR-26 financial summary reports are submitted as part of the Consolidated Annual Performance Evaluation Report (CAPER). This report should include all expenditures for the program year, including accrued expenditures.
Condition. During our audit procedures over the City's annual PR-26 reports and the annual CAPER, we noted that none of the reports were subject to an independent review and approval prior to submission in order to detect and correct potential errors or omissions. We also noted that the CAPER was submitted as required, but contained financial data that did not agree to the City's underlying accounting records for the reporting period as required. The City's annual PR-26 report did not agree to the annual CAPER by approximately $435,000 and needed to be resubmitted to HUD.
Cause. This condition appears to have been caused by a lack of complete knowledge of applicable federal compliance requirements and employee turnover in the economic development department.
Effect. As a result of this condition, the City did not fully comply with the requirements of the grant and filed reports that contained financial errors.
Questioned Costs. No costs have been questioned as a result of this finding as the reports did not serve as a basis for cost-reimbursement.
Recommendation. We recommend that reports required to be submitted to the oversight agency that contain financial information be reviewed and approved by the finance department to ensure accuracy of the financial information.
View of Responsible Officials. The City acknowledges the issues noted with reporting in the Community Development Block Grant Program. Finance and Community Development will work together to strengthen programmatic and financial reporting so that it is both timely and accurate. Staff working on this grant are new to their positions since the last time the program was audited, and are committed to reviewing policies and procedures to make sure reporting is completed appropriately.
Responsible Officials. Revenue Services Director and Community Services Director
Estimated Completion Date. June 30, 2025
2024-004 – Inaccurate Reporting/Lack of Independent Review and Approval of Reporting
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Reporting).
Federal program(s)
U.S. Department of Housing and Urban Development -
Community Development Block Grants/Entitlement Grants (ALN 14.218); Direct award; All project numbers.
Criteria. Recipients of federal awards are required to report periodically on financial information, as specified by the 2 CFR 200 Compliance Supplement or grant agreement. Reported information should be supported by the entity’s accounting records and subjected to an independent review and approval prior to submission in order to detect and correct any errors or omissions. Additionally, the PR-26 financial summary reports are submitted as part of the Consolidated Annual Performance Evaluation Report (CAPER). This report should include all expenditures for the program year, including accrued expenditures.
Condition. During our audit procedures over the City's annual PR-26 reports and the annual CAPER, we noted that none of the reports were subject to an independent review and approval prior to submission in order to detect and correct potential errors or omissions. We also noted that the CAPER was submitted as required, but contained financial data that did not agree to the City's underlying accounting records for the reporting period as required. The City's annual PR-26 report did not agree to the annual CAPER by approximately $435,000 and needed to be resubmitted to HUD.
Cause. This condition appears to have been caused by a lack of complete knowledge of applicable federal compliance requirements and employee turnover in the economic development department.
Effect. As a result of this condition, the City did not fully comply with the requirements of the grant and filed reports that contained financial errors.
Questioned Costs. No costs have been questioned as a result of this finding as the reports did not serve as a basis for cost-reimbursement.
Recommendation. We recommend that reports required to be submitted to the oversight agency that contain financial information be reviewed and approved by the finance department to ensure accuracy of the financial information.
View of Responsible Officials. The City acknowledges the issues noted with reporting in the Community Development Block Grant Program. Finance and Community Development will work together to strengthen programmatic and financial reporting so that it is both timely and accurate. Staff working on this grant are new to their positions since the last time the program was audited, and are committed to reviewing policies and procedures to make sure reporting is completed appropriately.
Responsible Officials. Revenue Services Director and Community Services Director
Estimated Completion Date. June 30, 2025
2024-005 – Blood Lead Testing
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Special Tests and Provisions).
Federal program(s)
U.S. Department of Housing and Urban Development -
Lead Hazard Reduction Grant Program (ALN 14.905); Direct award; All project numbers.
Criteria. The U.S. Department of Housing and Urban Development (HUD) requires that applicants should request testing of each child under the age of six years who reside in a housing unit under contract to receive lead hazard control work, or document that a child has been tested for blood levels within the six months preceding the lead control work, unless it is documented that the child's parent or legal guardian chooses not to have the child tested.
Condition. During our testing of applicant files, the City did not require blood testing for each child under the age of six who resided in the housing unit for one out of the five files selected for testing. It was also noted that the child's parent or legal guardian did not decline to have the child's blood tested.
Cause. Management does not appear to have sufficient internal control procedures in place to properly implement all of HUD's program requirements.
Effect. As a result of this condition, the City did not follow HUD guidelines to ensure that blood lead testing was performed in accordance with the grant requirements.
Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs were identified.
Recommendation. We recommend that the City implement policies and procedures to ensure that blood lead testing is complete for all applicants with children under the age of six who reside in the housing unit.
View of Responsible Officials. The City acknowledges the issue noted with Blood Lead Testing. The lack of testing occurred prior to current management taking over the program. All blood lead testing under current management is believed to be in compliance with program guidelines. Since January, 2024 the program has only served families with known lead poisoning with children 6 or under.
Responsible Officials. Community Services Director
Estimated Completion Date. June 30, 2025
2024-002 – Federal Funding Accountability and Transparency Act (FFATA) Reporting
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Reporting).
Federal program(s)
U.S. Department of Housing and Urban Development:
Community Development Block Grants/Entitlement Grants (ALN 14.218); Direct award; All project numbers.
Lead Hazard Reduction Grant Program (ALN 14.905); Direct award; All project numbers.
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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000.
Condition. The City did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance.
Cause. The City does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance.
Effect. The City did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients.
Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs were identified.
Recommendation. We recommend that the City review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward.
View of Responsible Officials. The City acknowledges reporting has lapsed in this system. New procedures have been put in place to ensure reporting occurs in a timely manner and there is oversight of the reporting throughout the year. These procedures include additional questions on internal documents regarding potential subrecipients, as well as monitoring Commission agendas, and regular reporting reminders.
Responsible Officials. Revenue Services Director
Estimated Completion Date. June 30, 2025
2024-002 – Federal Funding Accountability and Transparency Act (FFATA) Reporting
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Reporting).
Federal program(s)
U.S. Department of Housing and Urban Development:
Community Development Block Grants/Entitlement Grants (ALN 14.218); Direct award; All project numbers.
Lead Hazard Reduction Grant Program (ALN 14.905); Direct award; All project numbers.
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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000.
Condition. The City did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance.
Cause. The City does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance.
Effect. The City did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients.
Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs were identified.
Recommendation. We recommend that the City review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward.
View of Responsible Officials. The City acknowledges reporting has lapsed in this system. New procedures have been put in place to ensure reporting occurs in a timely manner and there is oversight of the reporting throughout the year. These procedures include additional questions on internal documents regarding potential subrecipients, as well as monitoring Commission agendas, and regular reporting reminders.
Responsible Officials. Revenue Services Director
Estimated Completion Date. June 30, 2025
2024-002 – Federal Funding Accountability and Transparency Act (FFATA) Reporting
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Reporting).
Federal program(s)
U.S. Department of Housing and Urban Development:
Community Development Block Grants/Entitlement Grants (ALN 14.218); Direct award; All project numbers.
Lead Hazard Reduction Grant Program (ALN 14.905); Direct award; All project numbers.
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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000.
Condition. The City did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance.
Cause. The City does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance.
Effect. The City did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients.
Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs were identified.
Recommendation. We recommend that the City review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward.
View of Responsible Officials. The City acknowledges reporting has lapsed in this system. New procedures have been put in place to ensure reporting occurs in a timely manner and there is oversight of the reporting throughout the year. These procedures include additional questions on internal documents regarding potential subrecipients, as well as monitoring Commission agendas, and regular reporting reminders.
Responsible Officials. Revenue Services Director
Estimated Completion Date. June 30, 2025
2024-002 – Federal Funding Accountability and Transparency Act (FFATA) Reporting
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Reporting).
Federal program(s)
U.S. Department of Housing and Urban Development:
Community Development Block Grants/Entitlement Grants (ALN 14.218); Direct award; All project numbers.
Lead Hazard Reduction Grant Program (ALN 14.905); Direct award; All project numbers.
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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000.
Condition. The City did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance.
Cause. The City does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance.
Effect. The City did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients.
Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs were identified.
Recommendation. We recommend that the City review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward.
View of Responsible Officials. The City acknowledges reporting has lapsed in this system. New procedures have been put in place to ensure reporting occurs in a timely manner and there is oversight of the reporting throughout the year. These procedures include additional questions on internal documents regarding potential subrecipients, as well as monitoring Commission agendas, and regular reporting reminders.
Responsible Officials. Revenue Services Director
Estimated Completion Date. June 30, 2025
2024-002 – Federal Funding Accountability and Transparency Act (FFATA) Reporting
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Reporting).
Federal program(s)
U.S. Department of Housing and Urban Development:
Community Development Block Grants/Entitlement Grants (ALN 14.218); Direct award; All project numbers.
Lead Hazard Reduction Grant Program (ALN 14.905); Direct award; All project numbers.
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). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000.
Condition. The City did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance.
Cause. The City does not have the proper internal controls in place to ensure that FFATA reporting is completed promptly in accordance with the requirements of the Uniform Guidance.
Effect. The City did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients.
Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs were identified.
Recommendation. We recommend that the City review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward.
View of Responsible Officials. The City acknowledges reporting has lapsed in this system. New procedures have been put in place to ensure reporting occurs in a timely manner and there is oversight of the reporting throughout the year. These procedures include additional questions on internal documents regarding potential subrecipients, as well as monitoring Commission agendas, and regular reporting reminders.
Responsible Officials. Revenue Services Director
Estimated Completion Date. June 30, 2025
2024-003 – Timely Reporting
Federal program(s)
U.S. Department of Housing and Urban Development -
Lead Hazard Reduction Grant Program (ALN 14.905); Direct award; All project numbers.
Criteria. Recipients of federal awards are required to report periodically on financial information, as specified by the 2 CFR 200 Compliance Supplement or grant agreement. Reported information should be supported by the entity’s accounting records and subjected to an independent review and approval prior to submission in order to detect and correct any errors or omissions. Quarterly SF-425 reports are due no later than January 30, April 30, July 31, and October 31 for the preceding quarter. Additionally, HUD requires recipients that provide HUD-program benefits to individuals or families to report data on race, ethnicity and other data annually by using form HUD-27061, which must be submitted annually by January 10.
Condition. During our audit procedures over the City's reporting process, we noted that the City did not submit the quarterly SF-425 reports for fiscal year by the deadlines outlined in the grant agreements. Additionally, it was noted that the City did not complete and submit the required race and ethnic data for fiscal year 2024 using form HUD-27061.
Cause. This condition was caused by the lack of understanding by program staff of the specific requirements of reporting on forms SF-425 and HUD-27061.
Effect. As a result of this condition, the City did not comply fully with the reporting requirements under this federal award. In addition, the City was exposed to an increased risk that the reports filed could contain errors and not be detected and corrected on a timely basis.
Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs were identified.
Recommendation. We recommend that the City establish procedures to ensure that the HUD-27061 form is completed. We also recommend that all required reports are filed by their deadlines.
View of Responsible Officials. The City acknowledges the SF-425 reports for the Lead Hazard Reduction Grant Program were not timely submitted. Finance and Community Development will work together to strengthen financial reporting so that it is timely moving forward. Staff working on this grant are new to their positions since the last time the program was audited, and are committed to reviewing policies and procedures to make sure reporting is completed appropriately. Community Development will work with HUD to clarify the use of form HUD-27061.
Responsible Officials. Revenue Services Director and Community Services Director
Estimated Completion Date. June 30, 2025
2024-004 – Inaccurate Reporting/Lack of Independent Review and Approval of Reporting
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Reporting).
Federal program(s)
U.S. Department of Housing and Urban Development -
Community Development Block Grants/Entitlement Grants (ALN 14.218); Direct award; All project numbers.
Criteria. Recipients of federal awards are required to report periodically on financial information, as specified by the 2 CFR 200 Compliance Supplement or grant agreement. Reported information should be supported by the entity’s accounting records and subjected to an independent review and approval prior to submission in order to detect and correct any errors or omissions. Additionally, the PR-26 financial summary reports are submitted as part of the Consolidated Annual Performance Evaluation Report (CAPER). This report should include all expenditures for the program year, including accrued expenditures.
Condition. During our audit procedures over the City's annual PR-26 reports and the annual CAPER, we noted that none of the reports were subject to an independent review and approval prior to submission in order to detect and correct potential errors or omissions. We also noted that the CAPER was submitted as required, but contained financial data that did not agree to the City's underlying accounting records for the reporting period as required. The City's annual PR-26 report did not agree to the annual CAPER by approximately $435,000 and needed to be resubmitted to HUD.
Cause. This condition appears to have been caused by a lack of complete knowledge of applicable federal compliance requirements and employee turnover in the economic development department.
Effect. As a result of this condition, the City did not fully comply with the requirements of the grant and filed reports that contained financial errors.
Questioned Costs. No costs have been questioned as a result of this finding as the reports did not serve as a basis for cost-reimbursement.
Recommendation. We recommend that reports required to be submitted to the oversight agency that contain financial information be reviewed and approved by the finance department to ensure accuracy of the financial information.
View of Responsible Officials. The City acknowledges the issues noted with reporting in the Community Development Block Grant Program. Finance and Community Development will work together to strengthen programmatic and financial reporting so that it is both timely and accurate. Staff working on this grant are new to their positions since the last time the program was audited, and are committed to reviewing policies and procedures to make sure reporting is completed appropriately.
Responsible Officials. Revenue Services Director and Community Services Director
Estimated Completion Date. June 30, 2025
2024-004 – Inaccurate Reporting/Lack of Independent Review and Approval of Reporting
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Reporting).
Federal program(s)
U.S. Department of Housing and Urban Development -
Community Development Block Grants/Entitlement Grants (ALN 14.218); Direct award; All project numbers.
Criteria. Recipients of federal awards are required to report periodically on financial information, as specified by the 2 CFR 200 Compliance Supplement or grant agreement. Reported information should be supported by the entity’s accounting records and subjected to an independent review and approval prior to submission in order to detect and correct any errors or omissions. Additionally, the PR-26 financial summary reports are submitted as part of the Consolidated Annual Performance Evaluation Report (CAPER). This report should include all expenditures for the program year, including accrued expenditures.
Condition. During our audit procedures over the City's annual PR-26 reports and the annual CAPER, we noted that none of the reports were subject to an independent review and approval prior to submission in order to detect and correct potential errors or omissions. We also noted that the CAPER was submitted as required, but contained financial data that did not agree to the City's underlying accounting records for the reporting period as required. The City's annual PR-26 report did not agree to the annual CAPER by approximately $435,000 and needed to be resubmitted to HUD.
Cause. This condition appears to have been caused by a lack of complete knowledge of applicable federal compliance requirements and employee turnover in the economic development department.
Effect. As a result of this condition, the City did not fully comply with the requirements of the grant and filed reports that contained financial errors.
Questioned Costs. No costs have been questioned as a result of this finding as the reports did not serve as a basis for cost-reimbursement.
Recommendation. We recommend that reports required to be submitted to the oversight agency that contain financial information be reviewed and approved by the finance department to ensure accuracy of the financial information.
View of Responsible Officials. The City acknowledges the issues noted with reporting in the Community Development Block Grant Program. Finance and Community Development will work together to strengthen programmatic and financial reporting so that it is both timely and accurate. Staff working on this grant are new to their positions since the last time the program was audited, and are committed to reviewing policies and procedures to make sure reporting is completed appropriately.
Responsible Officials. Revenue Services Director and Community Services Director
Estimated Completion Date. June 30, 2025
2024-004 – Inaccurate Reporting/Lack of Independent Review and Approval of Reporting
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Reporting).
Federal program(s)
U.S. Department of Housing and Urban Development -
Community Development Block Grants/Entitlement Grants (ALN 14.218); Direct award; All project numbers.
Criteria. Recipients of federal awards are required to report periodically on financial information, as specified by the 2 CFR 200 Compliance Supplement or grant agreement. Reported information should be supported by the entity’s accounting records and subjected to an independent review and approval prior to submission in order to detect and correct any errors or omissions. Additionally, the PR-26 financial summary reports are submitted as part of the Consolidated Annual Performance Evaluation Report (CAPER). This report should include all expenditures for the program year, including accrued expenditures.
Condition. During our audit procedures over the City's annual PR-26 reports and the annual CAPER, we noted that none of the reports were subject to an independent review and approval prior to submission in order to detect and correct potential errors or omissions. We also noted that the CAPER was submitted as required, but contained financial data that did not agree to the City's underlying accounting records for the reporting period as required. The City's annual PR-26 report did not agree to the annual CAPER by approximately $435,000 and needed to be resubmitted to HUD.
Cause. This condition appears to have been caused by a lack of complete knowledge of applicable federal compliance requirements and employee turnover in the economic development department.
Effect. As a result of this condition, the City did not fully comply with the requirements of the grant and filed reports that contained financial errors.
Questioned Costs. No costs have been questioned as a result of this finding as the reports did not serve as a basis for cost-reimbursement.
Recommendation. We recommend that reports required to be submitted to the oversight agency that contain financial information be reviewed and approved by the finance department to ensure accuracy of the financial information.
View of Responsible Officials. The City acknowledges the issues noted with reporting in the Community Development Block Grant Program. Finance and Community Development will work together to strengthen programmatic and financial reporting so that it is both timely and accurate. Staff working on this grant are new to their positions since the last time the program was audited, and are committed to reviewing policies and procedures to make sure reporting is completed appropriately.
Responsible Officials. Revenue Services Director and Community Services Director
Estimated Completion Date. June 30, 2025
2024-004 – Inaccurate Reporting/Lack of Independent Review and Approval of Reporting
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Reporting).
Federal program(s)
U.S. Department of Housing and Urban Development -
Community Development Block Grants/Entitlement Grants (ALN 14.218); Direct award; All project numbers.
Criteria. Recipients of federal awards are required to report periodically on financial information, as specified by the 2 CFR 200 Compliance Supplement or grant agreement. Reported information should be supported by the entity’s accounting records and subjected to an independent review and approval prior to submission in order to detect and correct any errors or omissions. Additionally, the PR-26 financial summary reports are submitted as part of the Consolidated Annual Performance Evaluation Report (CAPER). This report should include all expenditures for the program year, including accrued expenditures.
Condition. During our audit procedures over the City's annual PR-26 reports and the annual CAPER, we noted that none of the reports were subject to an independent review and approval prior to submission in order to detect and correct potential errors or omissions. We also noted that the CAPER was submitted as required, but contained financial data that did not agree to the City's underlying accounting records for the reporting period as required. The City's annual PR-26 report did not agree to the annual CAPER by approximately $435,000 and needed to be resubmitted to HUD.
Cause. This condition appears to have been caused by a lack of complete knowledge of applicable federal compliance requirements and employee turnover in the economic development department.
Effect. As a result of this condition, the City did not fully comply with the requirements of the grant and filed reports that contained financial errors.
Questioned Costs. No costs have been questioned as a result of this finding as the reports did not serve as a basis for cost-reimbursement.
Recommendation. We recommend that reports required to be submitted to the oversight agency that contain financial information be reviewed and approved by the finance department to ensure accuracy of the financial information.
View of Responsible Officials. The City acknowledges the issues noted with reporting in the Community Development Block Grant Program. Finance and Community Development will work together to strengthen programmatic and financial reporting so that it is both timely and accurate. Staff working on this grant are new to their positions since the last time the program was audited, and are committed to reviewing policies and procedures to make sure reporting is completed appropriately.
Responsible Officials. Revenue Services Director and Community Services Director
Estimated Completion Date. June 30, 2025
2024-005 – Blood Lead Testing
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance (Special Tests and Provisions).
Federal program(s)
U.S. Department of Housing and Urban Development -
Lead Hazard Reduction Grant Program (ALN 14.905); Direct award; All project numbers.
Criteria. The U.S. Department of Housing and Urban Development (HUD) requires that applicants should request testing of each child under the age of six years who reside in a housing unit under contract to receive lead hazard control work, or document that a child has been tested for blood levels within the six months preceding the lead control work, unless it is documented that the child's parent or legal guardian chooses not to have the child tested.
Condition. During our testing of applicant files, the City did not require blood testing for each child under the age of six who resided in the housing unit for one out of the five files selected for testing. It was also noted that the child's parent or legal guardian did not decline to have the child's blood tested.
Cause. Management does not appear to have sufficient internal control procedures in place to properly implement all of HUD's program requirements.
Effect. As a result of this condition, the City did not follow HUD guidelines to ensure that blood lead testing was performed in accordance with the grant requirements.
Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs were identified.
Recommendation. We recommend that the City implement policies and procedures to ensure that blood lead testing is complete for all applicants with children under the age of six who reside in the housing unit.
View of Responsible Officials. The City acknowledges the issue noted with Blood Lead Testing. The lack of testing occurred prior to current management taking over the program. All blood lead testing under current management is believed to be in compliance with program guidelines. Since January, 2024 the program has only served families with known lead poisoning with children 6 or under.
Responsible Officials. Community Services Director
Estimated Completion Date. June 30, 2025