2023-011– Report Filing - 2022 and 2023 CAPER
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Consolidated Annual Performance and Evaluation Report (CAPER) (24 CFR 91.520) – A grantee’s CAPER, submitted through the IDIS e-Con Planning Suite, is due 90 days after the close of a jurisdiction’s program year.
Condition. As of the completion of audit fieldwork, the 2022 and 2023 CAPERs have not been filed.
Cause. The City does not have the proper internal controls in place to ensure that all required reporting is submitted in a timely manner.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all required reports are submitted in a timely manner.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-012– Support for Payroll Allocations
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Controls over Compliance (Allowable Costs/Cost Principles).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Per 2 CFR § 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity."
Condition. During testing it was noted that the actual amounts charged to the grant were initially charged using the allocation rates from the previous pay period, and subsequently adjusted to the proper amount through a manual journal entry. When factoring in the amounts of the journal entries, the amount charged to the grant still differed from the support provided for 3 items of the 29 tested.
Cause. The City does not have the proper internal controls in place to ensure that all allocations of personnel cost are allocated according to the support retained.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as the amount of likely questioned cost did not exceed the required threshold.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all allocations of personnel cost are allocated according to the support retained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-011– Report Filing - 2022 and 2023 CAPER
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Consolidated Annual Performance and Evaluation Report (CAPER) (24 CFR 91.520) – A grantee’s CAPER, submitted through the IDIS e-Con Planning Suite, is due 90 days after the close of a jurisdiction’s program year.
Condition. As of the completion of audit fieldwork, the 2022 and 2023 CAPERs have not been filed.
Cause. The City does not have the proper internal controls in place to ensure that all required reporting is submitted in a timely manner.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all required reports are submitted in a timely manner.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-012– Support for Payroll Allocations
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Controls over Compliance (Allowable Costs/Cost Principles).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Per 2 CFR § 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity."
Condition. During testing it was noted that the actual amounts charged to the grant were initially charged using the allocation rates from the previous pay period, and subsequently adjusted to the proper amount through a manual journal entry. When factoring in the amounts of the journal entries, the amount charged to the grant still differed from the support provided for 3 items of the 29 tested.
Cause. The City does not have the proper internal controls in place to ensure that all allocations of personnel cost are allocated according to the support retained.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as the amount of likely questioned cost did not exceed the required threshold.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all allocations of personnel cost are allocated according to the support retained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-011– Report Filing - 2022 and 2023 CAPER
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Consolidated Annual Performance and Evaluation Report (CAPER) (24 CFR 91.520) – A grantee’s CAPER, submitted through the IDIS e-Con Planning Suite, is due 90 days after the close of a jurisdiction’s program year.
Condition. As of the completion of audit fieldwork, the 2022 and 2023 CAPERs have not been filed.
Cause. The City does not have the proper internal controls in place to ensure that all required reporting is submitted in a timely manner.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all required reports are submitted in a timely manner.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-012– Support for Payroll Allocations
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Controls over Compliance (Allowable Costs/Cost Principles).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Per 2 CFR § 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity."
Condition. During testing it was noted that the actual amounts charged to the grant were initially charged using the allocation rates from the previous pay period, and subsequently adjusted to the proper amount through a manual journal entry. When factoring in the amounts of the journal entries, the amount charged to the grant still differed from the support provided for 3 items of the 29 tested.
Cause. The City does not have the proper internal controls in place to ensure that all allocations of personnel cost are allocated according to the support retained.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as the amount of likely questioned cost did not exceed the required threshold.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all allocations of personnel cost are allocated according to the support retained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-011– Report Filing - 2022 and 2023 CAPER
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Consolidated Annual Performance and Evaluation Report (CAPER) (24 CFR 91.520) – A grantee’s CAPER, submitted through the IDIS e-Con Planning Suite, is due 90 days after the close of a jurisdiction’s program year.
Condition. As of the completion of audit fieldwork, the 2022 and 2023 CAPERs have not been filed.
Cause. The City does not have the proper internal controls in place to ensure that all required reporting is submitted in a timely manner.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all required reports are submitted in a timely manner.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-012– Support for Payroll Allocations
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Controls over Compliance (Allowable Costs/Cost Principles).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Per 2 CFR § 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity."
Condition. During testing it was noted that the actual amounts charged to the grant were initially charged using the allocation rates from the previous pay period, and subsequently adjusted to the proper amount through a manual journal entry. When factoring in the amounts of the journal entries, the amount charged to the grant still differed from the support provided for 3 items of the 29 tested.
Cause. The City does not have the proper internal controls in place to ensure that all allocations of personnel cost are allocated according to the support retained.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as the amount of likely questioned cost did not exceed the required threshold.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all allocations of personnel cost are allocated according to the support retained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-011– Report Filing - 2022 and 2023 CAPER
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Consolidated Annual Performance and Evaluation Report (CAPER) (24 CFR 91.520) – A grantee’s CAPER, submitted through the IDIS e-Con Planning Suite, is due 90 days after the close of a jurisdiction’s program year.
Condition. As of the completion of audit fieldwork, the 2022 and 2023 CAPERs have not been filed.
Cause. The City does not have the proper internal controls in place to ensure that all required reporting is submitted in a timely manner.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all required reports are submitted in a timely manner.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-012– Support for Payroll Allocations
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Controls over Compliance (Allowable Costs/Cost Principles).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Per 2 CFR § 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity."
Condition. During testing it was noted that the actual amounts charged to the grant were initially charged using the allocation rates from the previous pay period, and subsequently adjusted to the proper amount through a manual journal entry. When factoring in the amounts of the journal entries, the amount charged to the grant still differed from the support provided for 3 items of the 29 tested.
Cause. The City does not have the proper internal controls in place to ensure that all allocations of personnel cost are allocated according to the support retained.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as the amount of likely questioned cost did not exceed the required threshold.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all allocations of personnel cost are allocated according to the support retained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-011– Report Filing - 2022 and 2023 CAPER
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Consolidated Annual Performance and Evaluation Report (CAPER) (24 CFR 91.520) – A grantee’s CAPER, submitted through the IDIS e-Con Planning Suite, is due 90 days after the close of a jurisdiction’s program year.
Condition. As of the completion of audit fieldwork, the 2022 and 2023 CAPERs have not been filed.
Cause. The City does not have the proper internal controls in place to ensure that all required reporting is submitted in a timely manner.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all required reports are submitted in a timely manner.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-012– Support for Payroll Allocations
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Controls over Compliance (Allowable Costs/Cost Principles).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Per 2 CFR § 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity."
Condition. During testing it was noted that the actual amounts charged to the grant were initially charged using the allocation rates from the previous pay period, and subsequently adjusted to the proper amount through a manual journal entry. When factoring in the amounts of the journal entries, the amount charged to the grant still differed from the support provided for 3 items of the 29 tested.
Cause. The City does not have the proper internal controls in place to ensure that all allocations of personnel cost are allocated according to the support retained.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as the amount of likely questioned cost did not exceed the required threshold.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all allocations of personnel cost are allocated according to the support retained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-011– Report Filing - 2022 and 2023 CAPER
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Consolidated Annual Performance and Evaluation Report (CAPER) (24 CFR 91.520) – A grantee’s CAPER, submitted through the IDIS e-Con Planning Suite, is due 90 days after the close of a jurisdiction’s program year.
Condition. As of the completion of audit fieldwork, the 2022 and 2023 CAPERs have not been filed.
Cause. The City does not have the proper internal controls in place to ensure that all required reporting is submitted in a timely manner.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all required reports are submitted in a timely manner.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-012– Support for Payroll Allocations
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Controls over Compliance (Allowable Costs/Cost Principles).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Per 2 CFR § 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity."
Condition. During testing it was noted that the actual amounts charged to the grant were initially charged using the allocation rates from the previous pay period, and subsequently adjusted to the proper amount through a manual journal entry. When factoring in the amounts of the journal entries, the amount charged to the grant still differed from the support provided for 3 items of the 29 tested.
Cause. The City does not have the proper internal controls in place to ensure that all allocations of personnel cost are allocated according to the support retained.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as the amount of likely questioned cost did not exceed the required threshold.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all allocations of personnel cost are allocated according to the support retained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-011– Report Filing - 2022 and 2023 CAPER
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Consolidated Annual Performance and Evaluation Report (CAPER) (24 CFR 91.520) – A grantee’s CAPER, submitted through the IDIS e-Con Planning Suite, is due 90 days after the close of a jurisdiction’s program year.
Condition. As of the completion of audit fieldwork, the 2022 and 2023 CAPERs have not been filed.
Cause. The City does not have the proper internal controls in place to ensure that all required reporting is submitted in a timely manner.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all required reports are submitted in a timely manner.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-012– Support for Payroll Allocations
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Controls over Compliance (Allowable Costs/Cost Principles).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Per 2 CFR § 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity."
Condition. During testing it was noted that the actual amounts charged to the grant were initially charged using the allocation rates from the previous pay period, and subsequently adjusted to the proper amount through a manual journal entry. When factoring in the amounts of the journal entries, the amount charged to the grant still differed from the support provided for 3 items of the 29 tested.
Cause. The City does not have the proper internal controls in place to ensure that all allocations of personnel cost are allocated according to the support retained.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as the amount of likely questioned cost did not exceed the required threshold.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all allocations of personnel cost are allocated according to the support retained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-008 – Suspension and Debarment (repeat finding)
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment).
Programs. Coronavirus State and Local Fiscal Recovery Funds (SLFRF); U.S. Department of Treasury; Assistance Listing Number 21.027.
Substance Abuse and Mental Health Services - Projects of Regional and National Significance; U.S. Department of Health and Human Services; Assistance Listing Number 93.243; Award Number 1H79SM084918-01.
Criteria. Recipients of federal awards are required to follow their own internal purchasing policies, as well as comply with purchasing standards set forth in the Uniform Guidance. Part of that guidance requires an entity to check if a vendor is suspended or debarred before entering into a contract.
Condition. The City was unable to provide documentation to support its consideration of suspension and debarment requirements for 7 out of 8 vendors selected for testing.
Cause. Management has indicated that the City is conducting proper procurement processes and checking for suspension and debarment, but does not have the proper internal controls in place to ensure that documentation of the verification is retained in accordance with federal requirements.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs, and the vendors in question were not actually suspended or debarred.
Recommendation. We recommend that the City implement necessary internal controls to ensure documentation of its compliance with the requirements of the Uniform Guidance is maintained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-010– Special Reporting for Federal Funding Accountability and Transparency Act
Finding Type. Immaterial Noncompliance/Sigificant Deficiency in Internal Control over Compliance (Reporting).
Programs. Choice Neighborhoods Implementation Grant; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.889' Award Number MI5F519CNG117.
Substance Abuse and Mental Health Services - Projects of Regional and National Significance; U.S. Department of Health and Human Services; Assistance Listing Number 93.243; Award Number 1H79SM084918-01.
Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Condition. Despite passing through qualifying amounts, the City could produce no evidence that the subawards had been reported through the FSRS.
Cause. The City does not have the proper internal controls in place to ensure that subaward reporting is submitted for all direct grants.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure that reporting of subawards greater than $30,000 is submitted to the FSRS for all direct grants.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-008 – Suspension and Debarment (repeat finding)
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment).
Programs. Coronavirus State and Local Fiscal Recovery Funds (SLFRF); U.S. Department of Treasury; Assistance Listing Number 21.027.
Substance Abuse and Mental Health Services - Projects of Regional and National Significance; U.S. Department of Health and Human Services; Assistance Listing Number 93.243; Award Number 1H79SM084918-01.
Criteria. Recipients of federal awards are required to follow their own internal purchasing policies, as well as comply with purchasing standards set forth in the Uniform Guidance. Part of that guidance requires an entity to check if a vendor is suspended or debarred before entering into a contract.
Condition. The City was unable to provide documentation to support its consideration of suspension and debarment requirements for 7 out of 8 vendors selected for testing.
Cause. Management has indicated that the City is conducting proper procurement processes and checking for suspension and debarment, but does not have the proper internal controls in place to ensure that documentation of the verification is retained in accordance with federal requirements.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs, and the vendors in question were not actually suspended or debarred.
Recommendation. We recommend that the City implement necessary internal controls to ensure documentation of its compliance with the requirements of the Uniform Guidance is maintained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-009 – Subrecipient Monitoring
Finding Type. Immaterial Noncompliance/Sigificant Deficiency in Internal Control over Compliance (Subrecipient Monitoring).
Program. Substance Abuse and Mental Health Services - Projects of Regional and National Significance; U.S. Department of Health and Human Services; Assistance Listing Number 93.243; Award Number 1H79SM084918-01.
Criteria. When a grant recipient makes subawards to other recipients, certain compliance requirements are required in order to monitor the activity of the subrecipients. The Uniform Guidance requires that the pass-through entity clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); (2) all requirements imposed by the Pass-Through Entity (PTE) on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). The Uniform Guidance further requires that the pass-through entity valuate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.331(b)). This evaluation of risk may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR part 200, subpart F, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency).
Condition. Subaward contracts review did not contain appropriate information related to the federal program. No assistance listing number or federal program name was noted in the language of the agreements. In addition, no evidence of formal risk assessment was documented.
Cause. The City does not have the proper internal controls in place to ensure that contract language contains all of the information required to be communicated under the Uniform Guidance or that documentation of the risk assessment process related to subrecipients of federal awards is maintained.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing of the monitoring process and tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure documentation of its compliance with the requirements of the Uniform Guidance is maintained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented. Part of the solution will be implementing grant management software.
2023-010– Special Reporting for Federal Funding Accountability and Transparency Act
Finding Type. Immaterial Noncompliance/Sigificant Deficiency in Internal Control over Compliance (Reporting).
Programs. Choice Neighborhoods Implementation Grant; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.889' Award Number MI5F519CNG117.
Substance Abuse and Mental Health Services - Projects of Regional and National Significance; U.S. Department of Health and Human Services; Assistance Listing Number 93.243; Award Number 1H79SM084918-01.
Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Condition. Despite passing through qualifying amounts, the City could produce no evidence that the subawards had been reported through the FSRS.
Cause. The City does not have the proper internal controls in place to ensure that subaward reporting is submitted for all direct grants.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure that reporting of subawards greater than $30,000 is submitted to the FSRS for all direct grants.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-011– Report Filing - 2022 and 2023 CAPER
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Consolidated Annual Performance and Evaluation Report (CAPER) (24 CFR 91.520) – A grantee’s CAPER, submitted through the IDIS e-Con Planning Suite, is due 90 days after the close of a jurisdiction’s program year.
Condition. As of the completion of audit fieldwork, the 2022 and 2023 CAPERs have not been filed.
Cause. The City does not have the proper internal controls in place to ensure that all required reporting is submitted in a timely manner.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all required reports are submitted in a timely manner.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-012– Support for Payroll Allocations
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Controls over Compliance (Allowable Costs/Cost Principles).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Per 2 CFR § 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity."
Condition. During testing it was noted that the actual amounts charged to the grant were initially charged using the allocation rates from the previous pay period, and subsequently adjusted to the proper amount through a manual journal entry. When factoring in the amounts of the journal entries, the amount charged to the grant still differed from the support provided for 3 items of the 29 tested.
Cause. The City does not have the proper internal controls in place to ensure that all allocations of personnel cost are allocated according to the support retained.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as the amount of likely questioned cost did not exceed the required threshold.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all allocations of personnel cost are allocated according to the support retained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-011– Report Filing - 2022 and 2023 CAPER
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Consolidated Annual Performance and Evaluation Report (CAPER) (24 CFR 91.520) – A grantee’s CAPER, submitted through the IDIS e-Con Planning Suite, is due 90 days after the close of a jurisdiction’s program year.
Condition. As of the completion of audit fieldwork, the 2022 and 2023 CAPERs have not been filed.
Cause. The City does not have the proper internal controls in place to ensure that all required reporting is submitted in a timely manner.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all required reports are submitted in a timely manner.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-012– Support for Payroll Allocations
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Controls over Compliance (Allowable Costs/Cost Principles).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Per 2 CFR § 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity."
Condition. During testing it was noted that the actual amounts charged to the grant were initially charged using the allocation rates from the previous pay period, and subsequently adjusted to the proper amount through a manual journal entry. When factoring in the amounts of the journal entries, the amount charged to the grant still differed from the support provided for 3 items of the 29 tested.
Cause. The City does not have the proper internal controls in place to ensure that all allocations of personnel cost are allocated according to the support retained.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as the amount of likely questioned cost did not exceed the required threshold.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all allocations of personnel cost are allocated according to the support retained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-011– Report Filing - 2022 and 2023 CAPER
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Consolidated Annual Performance and Evaluation Report (CAPER) (24 CFR 91.520) – A grantee’s CAPER, submitted through the IDIS e-Con Planning Suite, is due 90 days after the close of a jurisdiction’s program year.
Condition. As of the completion of audit fieldwork, the 2022 and 2023 CAPERs have not been filed.
Cause. The City does not have the proper internal controls in place to ensure that all required reporting is submitted in a timely manner.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all required reports are submitted in a timely manner.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-012– Support for Payroll Allocations
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Controls over Compliance (Allowable Costs/Cost Principles).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Per 2 CFR § 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity."
Condition. During testing it was noted that the actual amounts charged to the grant were initially charged using the allocation rates from the previous pay period, and subsequently adjusted to the proper amount through a manual journal entry. When factoring in the amounts of the journal entries, the amount charged to the grant still differed from the support provided for 3 items of the 29 tested.
Cause. The City does not have the proper internal controls in place to ensure that all allocations of personnel cost are allocated according to the support retained.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as the amount of likely questioned cost did not exceed the required threshold.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all allocations of personnel cost are allocated according to the support retained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-011– Report Filing - 2022 and 2023 CAPER
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Consolidated Annual Performance and Evaluation Report (CAPER) (24 CFR 91.520) – A grantee’s CAPER, submitted through the IDIS e-Con Planning Suite, is due 90 days after the close of a jurisdiction’s program year.
Condition. As of the completion of audit fieldwork, the 2022 and 2023 CAPERs have not been filed.
Cause. The City does not have the proper internal controls in place to ensure that all required reporting is submitted in a timely manner.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all required reports are submitted in a timely manner.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-012– Support for Payroll Allocations
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Controls over Compliance (Allowable Costs/Cost Principles).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Per 2 CFR § 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity."
Condition. During testing it was noted that the actual amounts charged to the grant were initially charged using the allocation rates from the previous pay period, and subsequently adjusted to the proper amount through a manual journal entry. When factoring in the amounts of the journal entries, the amount charged to the grant still differed from the support provided for 3 items of the 29 tested.
Cause. The City does not have the proper internal controls in place to ensure that all allocations of personnel cost are allocated according to the support retained.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as the amount of likely questioned cost did not exceed the required threshold.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all allocations of personnel cost are allocated according to the support retained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-011– Report Filing - 2022 and 2023 CAPER
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Consolidated Annual Performance and Evaluation Report (CAPER) (24 CFR 91.520) – A grantee’s CAPER, submitted through the IDIS e-Con Planning Suite, is due 90 days after the close of a jurisdiction’s program year.
Condition. As of the completion of audit fieldwork, the 2022 and 2023 CAPERs have not been filed.
Cause. The City does not have the proper internal controls in place to ensure that all required reporting is submitted in a timely manner.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all required reports are submitted in a timely manner.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-012– Support for Payroll Allocations
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Controls over Compliance (Allowable Costs/Cost Principles).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Per 2 CFR § 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity."
Condition. During testing it was noted that the actual amounts charged to the grant were initially charged using the allocation rates from the previous pay period, and subsequently adjusted to the proper amount through a manual journal entry. When factoring in the amounts of the journal entries, the amount charged to the grant still differed from the support provided for 3 items of the 29 tested.
Cause. The City does not have the proper internal controls in place to ensure that all allocations of personnel cost are allocated according to the support retained.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as the amount of likely questioned cost did not exceed the required threshold.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all allocations of personnel cost are allocated according to the support retained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-011– Report Filing - 2022 and 2023 CAPER
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Consolidated Annual Performance and Evaluation Report (CAPER) (24 CFR 91.520) – A grantee’s CAPER, submitted through the IDIS e-Con Planning Suite, is due 90 days after the close of a jurisdiction’s program year.
Condition. As of the completion of audit fieldwork, the 2022 and 2023 CAPERs have not been filed.
Cause. The City does not have the proper internal controls in place to ensure that all required reporting is submitted in a timely manner.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all required reports are submitted in a timely manner.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-012– Support for Payroll Allocations
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Controls over Compliance (Allowable Costs/Cost Principles).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Per 2 CFR § 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity."
Condition. During testing it was noted that the actual amounts charged to the grant were initially charged using the allocation rates from the previous pay period, and subsequently adjusted to the proper amount through a manual journal entry. When factoring in the amounts of the journal entries, the amount charged to the grant still differed from the support provided for 3 items of the 29 tested.
Cause. The City does not have the proper internal controls in place to ensure that all allocations of personnel cost are allocated according to the support retained.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as the amount of likely questioned cost did not exceed the required threshold.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all allocations of personnel cost are allocated according to the support retained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-011– Report Filing - 2022 and 2023 CAPER
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Consolidated Annual Performance and Evaluation Report (CAPER) (24 CFR 91.520) – A grantee’s CAPER, submitted through the IDIS e-Con Planning Suite, is due 90 days after the close of a jurisdiction’s program year.
Condition. As of the completion of audit fieldwork, the 2022 and 2023 CAPERs have not been filed.
Cause. The City does not have the proper internal controls in place to ensure that all required reporting is submitted in a timely manner.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all required reports are submitted in a timely manner.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-012– Support for Payroll Allocations
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Controls over Compliance (Allowable Costs/Cost Principles).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Per 2 CFR § 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity."
Condition. During testing it was noted that the actual amounts charged to the grant were initially charged using the allocation rates from the previous pay period, and subsequently adjusted to the proper amount through a manual journal entry. When factoring in the amounts of the journal entries, the amount charged to the grant still differed from the support provided for 3 items of the 29 tested.
Cause. The City does not have the proper internal controls in place to ensure that all allocations of personnel cost are allocated according to the support retained.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as the amount of likely questioned cost did not exceed the required threshold.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all allocations of personnel cost are allocated according to the support retained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-011– Report Filing - 2022 and 2023 CAPER
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Consolidated Annual Performance and Evaluation Report (CAPER) (24 CFR 91.520) – A grantee’s CAPER, submitted through the IDIS e-Con Planning Suite, is due 90 days after the close of a jurisdiction’s program year.
Condition. As of the completion of audit fieldwork, the 2022 and 2023 CAPERs have not been filed.
Cause. The City does not have the proper internal controls in place to ensure that all required reporting is submitted in a timely manner.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all required reports are submitted in a timely manner.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-012– Support for Payroll Allocations
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Controls over Compliance (Allowable Costs/Cost Principles).
Program. Community Block Grants/Entitlement Grants; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.218; All awards.
Criteria. Per 2 CFR § 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity."
Condition. During testing it was noted that the actual amounts charged to the grant were initially charged using the allocation rates from the previous pay period, and subsequently adjusted to the proper amount through a manual journal entry. When factoring in the amounts of the journal entries, the amount charged to the grant still differed from the support provided for 3 items of the 29 tested.
Cause. The City does not have the proper internal controls in place to ensure that all allocations of personnel cost are allocated according to the support retained.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as the amount of likely questioned cost did not exceed the required threshold.
Recommendation. We recommend that the City implement necessary internal controls to ensure that all allocations of personnel cost are allocated according to the support retained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-008 – Suspension and Debarment (repeat finding)
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment).
Programs. Coronavirus State and Local Fiscal Recovery Funds (SLFRF); U.S. Department of Treasury; Assistance Listing Number 21.027.
Substance Abuse and Mental Health Services - Projects of Regional and National Significance; U.S. Department of Health and Human Services; Assistance Listing Number 93.243; Award Number 1H79SM084918-01.
Criteria. Recipients of federal awards are required to follow their own internal purchasing policies, as well as comply with purchasing standards set forth in the Uniform Guidance. Part of that guidance requires an entity to check if a vendor is suspended or debarred before entering into a contract.
Condition. The City was unable to provide documentation to support its consideration of suspension and debarment requirements for 7 out of 8 vendors selected for testing.
Cause. Management has indicated that the City is conducting proper procurement processes and checking for suspension and debarment, but does not have the proper internal controls in place to ensure that documentation of the verification is retained in accordance with federal requirements.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs, and the vendors in question were not actually suspended or debarred.
Recommendation. We recommend that the City implement necessary internal controls to ensure documentation of its compliance with the requirements of the Uniform Guidance is maintained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-010– Special Reporting for Federal Funding Accountability and Transparency Act
Finding Type. Immaterial Noncompliance/Sigificant Deficiency in Internal Control over Compliance (Reporting).
Programs. Choice Neighborhoods Implementation Grant; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.889' Award Number MI5F519CNG117.
Substance Abuse and Mental Health Services - Projects of Regional and National Significance; U.S. Department of Health and Human Services; Assistance Listing Number 93.243; Award Number 1H79SM084918-01.
Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Condition. Despite passing through qualifying amounts, the City could produce no evidence that the subawards had been reported through the FSRS.
Cause. The City does not have the proper internal controls in place to ensure that subaward reporting is submitted for all direct grants.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure that reporting of subawards greater than $30,000 is submitted to the FSRS for all direct grants.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-008 – Suspension and Debarment (repeat finding)
Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment).
Programs. Coronavirus State and Local Fiscal Recovery Funds (SLFRF); U.S. Department of Treasury; Assistance Listing Number 21.027.
Substance Abuse and Mental Health Services - Projects of Regional and National Significance; U.S. Department of Health and Human Services; Assistance Listing Number 93.243; Award Number 1H79SM084918-01.
Criteria. Recipients of federal awards are required to follow their own internal purchasing policies, as well as comply with purchasing standards set forth in the Uniform Guidance. Part of that guidance requires an entity to check if a vendor is suspended or debarred before entering into a contract.
Condition. The City was unable to provide documentation to support its consideration of suspension and debarment requirements for 7 out of 8 vendors selected for testing.
Cause. Management has indicated that the City is conducting proper procurement processes and checking for suspension and debarment, but does not have the proper internal controls in place to ensure that documentation of the verification is retained in accordance with federal requirements.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs, and the vendors in question were not actually suspended or debarred.
Recommendation. We recommend that the City implement necessary internal controls to ensure documentation of its compliance with the requirements of the Uniform Guidance is maintained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.
2023-009 – Subrecipient Monitoring
Finding Type. Immaterial Noncompliance/Sigificant Deficiency in Internal Control over Compliance (Subrecipient Monitoring).
Program. Substance Abuse and Mental Health Services - Projects of Regional and National Significance; U.S. Department of Health and Human Services; Assistance Listing Number 93.243; Award Number 1H79SM084918-01.
Criteria. When a grant recipient makes subawards to other recipients, certain compliance requirements are required in order to monitor the activity of the subrecipients. The Uniform Guidance requires that the pass-through entity clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); (2) all requirements imposed by the Pass-Through Entity (PTE) on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). The Uniform Guidance further requires that the pass-through entity valuate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.331(b)). This evaluation of risk may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR part 200, subpart F, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency).
Condition. Subaward contracts review did not contain appropriate information related to the federal program. No assistance listing number or federal program name was noted in the language of the agreements. In addition, no evidence of formal risk assessment was documented.
Cause. The City does not have the proper internal controls in place to ensure that contract language contains all of the information required to be communicated under the Uniform Guidance or that documentation of the risk assessment process related to subrecipients of federal awards is maintained.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing of the monitoring process and tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure documentation of its compliance with the requirements of the Uniform Guidance is maintained.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented. Part of the solution will be implementing grant management software.
2023-010– Special Reporting for Federal Funding Accountability and Transparency Act
Finding Type. Immaterial Noncompliance/Sigificant Deficiency in Internal Control over Compliance (Reporting).
Programs. Choice Neighborhoods Implementation Grant; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.889' Award Number MI5F519CNG117.
Substance Abuse and Mental Health Services - Projects of Regional and National Significance; U.S. Department of Health and Human Services; Assistance Listing Number 93.243; Award Number 1H79SM084918-01.
Criteria. Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Condition. Despite passing through qualifying amounts, the City could produce no evidence that the subawards had been reported through the FSRS.
Cause. The City does not have the proper internal controls in place to ensure that subaward reporting is submitted for all direct grants.
Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls.
Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our tests of transactions did not indicate any unallowable costs.
Recommendation. We recommend that the City implement necessary internal controls to ensure that reporting of subawards greater than $30,000 is submitted to the FSRS for all direct grants.
View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented.