2024-003 – Reimbursement Requests (Significant Deficiency in Internal Controls over Compliance)
Federal Program Information
Federal Award Title and ALN: Federal Transit Cluster, 20.507, 20.526
Federal Awarding Agency: Department of Transportation
Federal Award ID Number: N/A
Federal Award Year: 2024
Federal Award Title and ALN: Airport Improvement Program, 20.106
Federal Awarding Agency: Department of Transportation, Federal Aviation Administration
Federal Award ID Number: SAF-SWG-3-35-0037-051-2020, SAF-SWG-3-35-0037-057-2021
Federal Award Year: 2024
Condition: The City submitted reimbursements for grants in an untimely fashion for multiple months at a
time in the Federal Transit Cluster and only at year-end in the Airport Improvement Program.
Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in
“Standards for Internal Control in the Federal Government” issued by the Comptroller General of the
United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.302b, the non-federal entity must provide for effective
control over, and accountability for, all funds, property, and other assets. The non-federal entity must
adequately safeguard all assets and assure that they are used solely for authorized purposes.
Cause: The City does not have sufficient controls in place to review and approve requests to submit as
needed.
Questioned Cost: None.
Effect: The City’s financial position and cash balances were adversely affected due to the delay in
requesting and receiving reimbursement for funds already disbursed. Significant time passing between
disbursement of funds and preparation of reimbursement requests may increase the chance of errors.
2024-004 (2023-004) – Activities Allowed, Allowable Costs over Payroll (Significant Deficiency in Internal
Controls over Compliance) (Repeated/Modified)
Federal Program Information
Federal Award Title and ALN: Airport Improvement Program, 20.106
Federal Awarding Agency: Department of Transportation, Federal Aviation Administration
Federal Award ID Number: SAF-SWG-3-35-0037-057-2021
Federal Award Year: 2024
Condition: Two payroll checks were duplicated and included in the request for reimbursement. These
checks totaled $2,694, out of a total of $876,014 in payroll charged to the program.
Management’s Progress on Repeat Findings: Some progress made from prior year.
Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in
“Standards for Internal Control in the Federal Government” issued by the Comptroller General of the
United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.430(f) – Factors affecting allowability of costs, costs charged to Federal programs
may not be included as a cost or used to meet cost sharing or matching requirements of any other
federally-financed program in either the current or a prior period.
Cause: The City does not have sufficient controls in place to ensure the accuracy of the amounts listed on
the general ledger as charged to the grant.
Questioned Cost: Known and likely questioned costs of $2,694
Effect: The City requested and received reimbursement for duplicate transactions not properly allocable
to the program in the amount of $2,694.
2024-005 (2023-006) – Equipment and Real Property Management (Material Weakness over Internal
Controls over Compliance) (Repeated/Modified)
Federal Program Information
Federal Award Title and ALN: Airport Improvement Program, 20.106
Federal Awarding Agency: Department of Transportation, Federal Aviation Administration
Federal Award ID Number: SAF-SWG-3-35-0037-051-2020
Federal Award Year: 2024
Condition: The City’s approved annual inventory was not complete. There was no information to identify
the funding source of the equipment and/or property.
Management’s Progress on Repeat Findings: Some progress made from prior year.
Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in
“Standards for Internal Control in the Federal Government” issued by the Comptroller General of the
United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Per 2 CFR 200.313(d)(1) Property records must be maintained that include a description of the property,
a serial number or other identification number, the source of funding for the property (including the FAIN),
who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the
project costs for the Federal award under which the property was acquired, the location, use and
condition of the property, and any ultimate disposition data including the date of disposal and sale price
of the property.
Cause: Turnover in related positions resulted in delays in making revisions to the listing to incorporate
information on Federal participation in the purchases.
Questioned Cost: None.
Effect: The City could dispose of federally funded equipment without following federal guidelines.
2024-003 – Reimbursement Requests (Significant Deficiency in Internal Controls over Compliance)
Federal Program Information
Federal Award Title and ALN: Federal Transit Cluster, 20.507, 20.526
Federal Awarding Agency: Department of Transportation
Federal Award ID Number: N/A
Federal Award Year: 2024
Federal Award Title and ALN: Airport Improvement Program, 20.106
Federal Awarding Agency: Department of Transportation, Federal Aviation Administration
Federal Award ID Number: SAF-SWG-3-35-0037-051-2020, SAF-SWG-3-35-0037-057-2021
Federal Award Year: 2024
Condition: The City submitted reimbursements for grants in an untimely fashion for multiple months at a
time in the Federal Transit Cluster and only at year-end in the Airport Improvement Program.
Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in
“Standards for Internal Control in the Federal Government” issued by the Comptroller General of the
United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.302b, the non-federal entity must provide for effective
control over, and accountability for, all funds, property, and other assets. The non-federal entity must
adequately safeguard all assets and assure that they are used solely for authorized purposes.
Cause: The City does not have sufficient controls in place to review and approve requests to submit as
needed.
Questioned Cost: None.
Effect: The City’s financial position and cash balances were adversely affected due to the delay in
requesting and receiving reimbursement for funds already disbursed. Significant time passing between
disbursement of funds and preparation of reimbursement requests may increase the chance of errors.
2024-004 (2023-004) – Activities Allowed, Allowable Costs over Payroll (Significant Deficiency in Internal
Controls over Compliance) (Repeated/Modified)
Federal Program Information
Federal Award Title and ALN: Airport Improvement Program, 20.106
Federal Awarding Agency: Department of Transportation, Federal Aviation Administration
Federal Award ID Number: SAF-SWG-3-35-0037-057-2021
Federal Award Year: 2024
Condition: Two payroll checks were duplicated and included in the request for reimbursement. These
checks totaled $2,694, out of a total of $876,014 in payroll charged to the program.
Management’s Progress on Repeat Findings: Some progress made from prior year.
Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in
“Standards for Internal Control in the Federal Government” issued by the Comptroller General of the
United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.430(f) – Factors affecting allowability of costs, costs charged to Federal programs
may not be included as a cost or used to meet cost sharing or matching requirements of any other
federally-financed program in either the current or a prior period.
Cause: The City does not have sufficient controls in place to ensure the accuracy of the amounts listed on
the general ledger as charged to the grant.
Questioned Cost: Known and likely questioned costs of $2,694
Effect: The City requested and received reimbursement for duplicate transactions not properly allocable
to the program in the amount of $2,694.
2024-005 (2023-006) – Equipment and Real Property Management (Material Weakness over Internal
Controls over Compliance) (Repeated/Modified)
Federal Program Information
Federal Award Title and ALN: Airport Improvement Program, 20.106
Federal Awarding Agency: Department of Transportation, Federal Aviation Administration
Federal Award ID Number: SAF-SWG-3-35-0037-051-2020
Federal Award Year: 2024
Condition: The City’s approved annual inventory was not complete. There was no information to identify
the funding source of the equipment and/or property.
Management’s Progress on Repeat Findings: Some progress made from prior year.
Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in
“Standards for Internal Control in the Federal Government” issued by the Comptroller General of the
United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Per 2 CFR 200.313(d)(1) Property records must be maintained that include a description of the property,
a serial number or other identification number, the source of funding for the property (including the FAIN),
who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the
project costs for the Federal award under which the property was acquired, the location, use and
condition of the property, and any ultimate disposition data including the date of disposal and sale price
of the property.
Cause: Turnover in related positions resulted in delays in making revisions to the listing to incorporate
information on Federal participation in the purchases.
Questioned Cost: None.
Effect: The City could dispose of federally funded equipment without following federal guidelines.
2024-003 – Reimbursement Requests (Significant Deficiency in Internal Controls over Compliance)
Federal Program Information
Federal Award Title and ALN: Federal Transit Cluster, 20.507, 20.526
Federal Awarding Agency: Department of Transportation
Federal Award ID Number: N/A
Federal Award Year: 2024
Federal Award Title and ALN: Airport Improvement Program, 20.106
Federal Awarding Agency: Department of Transportation, Federal Aviation Administration
Federal Award ID Number: SAF-SWG-3-35-0037-051-2020, SAF-SWG-3-35-0037-057-2021
Federal Award Year: 2024
Condition: The City submitted reimbursements for grants in an untimely fashion for multiple months at a
time in the Federal Transit Cluster and only at year-end in the Airport Improvement Program.
Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in
“Standards for Internal Control in the Federal Government” issued by the Comptroller General of the
United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.302b, the non-federal entity must provide for effective
control over, and accountability for, all funds, property, and other assets. The non-federal entity must
adequately safeguard all assets and assure that they are used solely for authorized purposes.
Cause: The City does not have sufficient controls in place to review and approve requests to submit as
needed.
Questioned Cost: None.
Effect: The City’s financial position and cash balances were adversely affected due to the delay in
requesting and receiving reimbursement for funds already disbursed. Significant time passing between
disbursement of funds and preparation of reimbursement requests may increase the chance of errors.
2024-003 – Reimbursement Requests (Significant Deficiency in Internal Controls over Compliance)
Federal Program Information
Federal Award Title and ALN: Federal Transit Cluster, 20.507, 20.526
Federal Awarding Agency: Department of Transportation
Federal Award ID Number: N/A
Federal Award Year: 2024
Federal Award Title and ALN: Airport Improvement Program, 20.106
Federal Awarding Agency: Department of Transportation, Federal Aviation Administration
Federal Award ID Number: SAF-SWG-3-35-0037-051-2020, SAF-SWG-3-35-0037-057-2021
Federal Award Year: 2024
Condition: The City submitted reimbursements for grants in an untimely fashion for multiple months at a
time in the Federal Transit Cluster and only at year-end in the Airport Improvement Program.
Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in
“Standards for Internal Control in the Federal Government” issued by the Comptroller General of the
United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.302b, the non-federal entity must provide for effective
control over, and accountability for, all funds, property, and other assets. The non-federal entity must
adequately safeguard all assets and assure that they are used solely for authorized purposes.
Cause: The City does not have sufficient controls in place to review and approve requests to submit as
needed.
Questioned Cost: None.
Effect: The City’s financial position and cash balances were adversely affected due to the delay in
requesting and receiving reimbursement for funds already disbursed. Significant time passing between
disbursement of funds and preparation of reimbursement requests may increase the chance of errors.
2024-003 – Reimbursement Requests (Significant Deficiency in Internal Controls over Compliance)
Federal Program Information
Federal Award Title and ALN: Federal Transit Cluster, 20.507, 20.526
Federal Awarding Agency: Department of Transportation
Federal Award ID Number: N/A
Federal Award Year: 2024
Federal Award Title and ALN: Airport Improvement Program, 20.106
Federal Awarding Agency: Department of Transportation, Federal Aviation Administration
Federal Award ID Number: SAF-SWG-3-35-0037-051-2020, SAF-SWG-3-35-0037-057-2021
Federal Award Year: 2024
Condition: The City submitted reimbursements for grants in an untimely fashion for multiple months at a
time in the Federal Transit Cluster and only at year-end in the Airport Improvement Program.
Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in
“Standards for Internal Control in the Federal Government” issued by the Comptroller General of the
United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.302b, the non-federal entity must provide for effective
control over, and accountability for, all funds, property, and other assets. The non-federal entity must
adequately safeguard all assets and assure that they are used solely for authorized purposes.
Cause: The City does not have sufficient controls in place to review and approve requests to submit as
needed.
Questioned Cost: None.
Effect: The City’s financial position and cash balances were adversely affected due to the delay in
requesting and receiving reimbursement for funds already disbursed. Significant time passing between
disbursement of funds and preparation of reimbursement requests may increase the chance of errors.
2024-006 – Subrecipient Monitoring (Significant Deficiency in Internal Controls over Compliance)
Federal Program Information
Federal Award Title and ALN: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds, 21.027
Federal Awarding Agency: Department of the Treasury
Federal Award ID Number: N/A
Federal Award Year: 2024
Condition: In 5 of 5 samples tested, there was no indication of the City review and approval on
performance reports required of the subrecipient to submit for monitoring. Other monitoring activities
were performed. One contract was reported as a subaward on the preliminary SEFA.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entities must establish and
maintain effective internal control over the Federal award that provides reasonable assurance that the
non-Federal entities is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General
of the United States or the “Internal Control Integrated Framework”, issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.332e(1), in monitoring a subrecipient, a pass-through
entity must review financial and performance reports.
Cause: Inconsistent application of controls throughout the year and with different subrecipients and
entities resulted in poor documentation of control activities, and misclassification of a contract as a
subaward.
Questioned Cost: None.
Effect: Inconsistent application of controls can result in noncompliance due to errors or fraud not being
prevented or detected by employees. The Uniform Guidance requires pass-through entities to review
reports submitted by subrecipients, and the City was not able to substantiate compliance with this
requirement.
2024-003 – Reimbursement Requests (Significant Deficiency in Internal Controls over Compliance)
Federal Program Information
Federal Award Title and ALN: Federal Transit Cluster, 20.507, 20.526
Federal Awarding Agency: Department of Transportation
Federal Award ID Number: N/A
Federal Award Year: 2024
Federal Award Title and ALN: Airport Improvement Program, 20.106
Federal Awarding Agency: Department of Transportation, Federal Aviation Administration
Federal Award ID Number: SAF-SWG-3-35-0037-051-2020, SAF-SWG-3-35-0037-057-2021
Federal Award Year: 2024
Condition: The City submitted reimbursements for grants in an untimely fashion for multiple months at a
time in the Federal Transit Cluster and only at year-end in the Airport Improvement Program.
Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in
“Standards for Internal Control in the Federal Government” issued by the Comptroller General of the
United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.302b, the non-federal entity must provide for effective
control over, and accountability for, all funds, property, and other assets. The non-federal entity must
adequately safeguard all assets and assure that they are used solely for authorized purposes.
Cause: The City does not have sufficient controls in place to review and approve requests to submit as
needed.
Questioned Cost: None.
Effect: The City’s financial position and cash balances were adversely affected due to the delay in
requesting and receiving reimbursement for funds already disbursed. Significant time passing between
disbursement of funds and preparation of reimbursement requests may increase the chance of errors.
2024-004 (2023-004) – Activities Allowed, Allowable Costs over Payroll (Significant Deficiency in Internal
Controls over Compliance) (Repeated/Modified)
Federal Program Information
Federal Award Title and ALN: Airport Improvement Program, 20.106
Federal Awarding Agency: Department of Transportation, Federal Aviation Administration
Federal Award ID Number: SAF-SWG-3-35-0037-057-2021
Federal Award Year: 2024
Condition: Two payroll checks were duplicated and included in the request for reimbursement. These
checks totaled $2,694, out of a total of $876,014 in payroll charged to the program.
Management’s Progress on Repeat Findings: Some progress made from prior year.
Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in
“Standards for Internal Control in the Federal Government” issued by the Comptroller General of the
United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.430(f) – Factors affecting allowability of costs, costs charged to Federal programs
may not be included as a cost or used to meet cost sharing or matching requirements of any other
federally-financed program in either the current or a prior period.
Cause: The City does not have sufficient controls in place to ensure the accuracy of the amounts listed on
the general ledger as charged to the grant.
Questioned Cost: Known and likely questioned costs of $2,694
Effect: The City requested and received reimbursement for duplicate transactions not properly allocable
to the program in the amount of $2,694.
2024-005 (2023-006) – Equipment and Real Property Management (Material Weakness over Internal
Controls over Compliance) (Repeated/Modified)
Federal Program Information
Federal Award Title and ALN: Airport Improvement Program, 20.106
Federal Awarding Agency: Department of Transportation, Federal Aviation Administration
Federal Award ID Number: SAF-SWG-3-35-0037-051-2020
Federal Award Year: 2024
Condition: The City’s approved annual inventory was not complete. There was no information to identify
the funding source of the equipment and/or property.
Management’s Progress on Repeat Findings: Some progress made from prior year.
Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in
“Standards for Internal Control in the Federal Government” issued by the Comptroller General of the
United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Per 2 CFR 200.313(d)(1) Property records must be maintained that include a description of the property,
a serial number or other identification number, the source of funding for the property (including the FAIN),
who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the
project costs for the Federal award under which the property was acquired, the location, use and
condition of the property, and any ultimate disposition data including the date of disposal and sale price
of the property.
Cause: Turnover in related positions resulted in delays in making revisions to the listing to incorporate
information on Federal participation in the purchases.
Questioned Cost: None.
Effect: The City could dispose of federally funded equipment without following federal guidelines.
2024-003 – Reimbursement Requests (Significant Deficiency in Internal Controls over Compliance)
Federal Program Information
Federal Award Title and ALN: Federal Transit Cluster, 20.507, 20.526
Federal Awarding Agency: Department of Transportation
Federal Award ID Number: N/A
Federal Award Year: 2024
Federal Award Title and ALN: Airport Improvement Program, 20.106
Federal Awarding Agency: Department of Transportation, Federal Aviation Administration
Federal Award ID Number: SAF-SWG-3-35-0037-051-2020, SAF-SWG-3-35-0037-057-2021
Federal Award Year: 2024
Condition: The City submitted reimbursements for grants in an untimely fashion for multiple months at a
time in the Federal Transit Cluster and only at year-end in the Airport Improvement Program.
Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in
“Standards for Internal Control in the Federal Government” issued by the Comptroller General of the
United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.302b, the non-federal entity must provide for effective
control over, and accountability for, all funds, property, and other assets. The non-federal entity must
adequately safeguard all assets and assure that they are used solely for authorized purposes.
Cause: The City does not have sufficient controls in place to review and approve requests to submit as
needed.
Questioned Cost: None.
Effect: The City’s financial position and cash balances were adversely affected due to the delay in
requesting and receiving reimbursement for funds already disbursed. Significant time passing between
disbursement of funds and preparation of reimbursement requests may increase the chance of errors.
2024-004 (2023-004) – Activities Allowed, Allowable Costs over Payroll (Significant Deficiency in Internal
Controls over Compliance) (Repeated/Modified)
Federal Program Information
Federal Award Title and ALN: Airport Improvement Program, 20.106
Federal Awarding Agency: Department of Transportation, Federal Aviation Administration
Federal Award ID Number: SAF-SWG-3-35-0037-057-2021
Federal Award Year: 2024
Condition: Two payroll checks were duplicated and included in the request for reimbursement. These
checks totaled $2,694, out of a total of $876,014 in payroll charged to the program.
Management’s Progress on Repeat Findings: Some progress made from prior year.
Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in
“Standards for Internal Control in the Federal Government” issued by the Comptroller General of the
United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.430(f) – Factors affecting allowability of costs, costs charged to Federal programs
may not be included as a cost or used to meet cost sharing or matching requirements of any other
federally-financed program in either the current or a prior period.
Cause: The City does not have sufficient controls in place to ensure the accuracy of the amounts listed on
the general ledger as charged to the grant.
Questioned Cost: Known and likely questioned costs of $2,694
Effect: The City requested and received reimbursement for duplicate transactions not properly allocable
to the program in the amount of $2,694.
2024-005 (2023-006) – Equipment and Real Property Management (Material Weakness over Internal
Controls over Compliance) (Repeated/Modified)
Federal Program Information
Federal Award Title and ALN: Airport Improvement Program, 20.106
Federal Awarding Agency: Department of Transportation, Federal Aviation Administration
Federal Award ID Number: SAF-SWG-3-35-0037-051-2020
Federal Award Year: 2024
Condition: The City’s approved annual inventory was not complete. There was no information to identify
the funding source of the equipment and/or property.
Management’s Progress on Repeat Findings: Some progress made from prior year.
Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in
“Standards for Internal Control in the Federal Government” issued by the Comptroller General of the
United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Per 2 CFR 200.313(d)(1) Property records must be maintained that include a description of the property,
a serial number or other identification number, the source of funding for the property (including the FAIN),
who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the
project costs for the Federal award under which the property was acquired, the location, use and
condition of the property, and any ultimate disposition data including the date of disposal and sale price
of the property.
Cause: Turnover in related positions resulted in delays in making revisions to the listing to incorporate
information on Federal participation in the purchases.
Questioned Cost: None.
Effect: The City could dispose of federally funded equipment without following federal guidelines.
2024-003 – Reimbursement Requests (Significant Deficiency in Internal Controls over Compliance)
Federal Program Information
Federal Award Title and ALN: Federal Transit Cluster, 20.507, 20.526
Federal Awarding Agency: Department of Transportation
Federal Award ID Number: N/A
Federal Award Year: 2024
Federal Award Title and ALN: Airport Improvement Program, 20.106
Federal Awarding Agency: Department of Transportation, Federal Aviation Administration
Federal Award ID Number: SAF-SWG-3-35-0037-051-2020, SAF-SWG-3-35-0037-057-2021
Federal Award Year: 2024
Condition: The City submitted reimbursements for grants in an untimely fashion for multiple months at a
time in the Federal Transit Cluster and only at year-end in the Airport Improvement Program.
Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in
“Standards for Internal Control in the Federal Government” issued by the Comptroller General of the
United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.302b, the non-federal entity must provide for effective
control over, and accountability for, all funds, property, and other assets. The non-federal entity must
adequately safeguard all assets and assure that they are used solely for authorized purposes.
Cause: The City does not have sufficient controls in place to review and approve requests to submit as
needed.
Questioned Cost: None.
Effect: The City’s financial position and cash balances were adversely affected due to the delay in
requesting and receiving reimbursement for funds already disbursed. Significant time passing between
disbursement of funds and preparation of reimbursement requests may increase the chance of errors.
2024-003 – Reimbursement Requests (Significant Deficiency in Internal Controls over Compliance)
Federal Program Information
Federal Award Title and ALN: Federal Transit Cluster, 20.507, 20.526
Federal Awarding Agency: Department of Transportation
Federal Award ID Number: N/A
Federal Award Year: 2024
Federal Award Title and ALN: Airport Improvement Program, 20.106
Federal Awarding Agency: Department of Transportation, Federal Aviation Administration
Federal Award ID Number: SAF-SWG-3-35-0037-051-2020, SAF-SWG-3-35-0037-057-2021
Federal Award Year: 2024
Condition: The City submitted reimbursements for grants in an untimely fashion for multiple months at a
time in the Federal Transit Cluster and only at year-end in the Airport Improvement Program.
Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in
“Standards for Internal Control in the Federal Government” issued by the Comptroller General of the
United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.302b, the non-federal entity must provide for effective
control over, and accountability for, all funds, property, and other assets. The non-federal entity must
adequately safeguard all assets and assure that they are used solely for authorized purposes.
Cause: The City does not have sufficient controls in place to review and approve requests to submit as
needed.
Questioned Cost: None.
Effect: The City’s financial position and cash balances were adversely affected due to the delay in
requesting and receiving reimbursement for funds already disbursed. Significant time passing between
disbursement of funds and preparation of reimbursement requests may increase the chance of errors.
2024-003 – Reimbursement Requests (Significant Deficiency in Internal Controls over Compliance)
Federal Program Information
Federal Award Title and ALN: Federal Transit Cluster, 20.507, 20.526
Federal Awarding Agency: Department of Transportation
Federal Award ID Number: N/A
Federal Award Year: 2024
Federal Award Title and ALN: Airport Improvement Program, 20.106
Federal Awarding Agency: Department of Transportation, Federal Aviation Administration
Federal Award ID Number: SAF-SWG-3-35-0037-051-2020, SAF-SWG-3-35-0037-057-2021
Federal Award Year: 2024
Condition: The City submitted reimbursements for grants in an untimely fashion for multiple months at a
time in the Federal Transit Cluster and only at year-end in the Airport Improvement Program.
Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in
“Standards for Internal Control in the Federal Government” issued by the Comptroller General of the
United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.302b, the non-federal entity must provide for effective
control over, and accountability for, all funds, property, and other assets. The non-federal entity must
adequately safeguard all assets and assure that they are used solely for authorized purposes.
Cause: The City does not have sufficient controls in place to review and approve requests to submit as
needed.
Questioned Cost: None.
Effect: The City’s financial position and cash balances were adversely affected due to the delay in
requesting and receiving reimbursement for funds already disbursed. Significant time passing between
disbursement of funds and preparation of reimbursement requests may increase the chance of errors.
2024-006 – Subrecipient Monitoring (Significant Deficiency in Internal Controls over Compliance)
Federal Program Information
Federal Award Title and ALN: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds, 21.027
Federal Awarding Agency: Department of the Treasury
Federal Award ID Number: N/A
Federal Award Year: 2024
Condition: In 5 of 5 samples tested, there was no indication of the City review and approval on
performance reports required of the subrecipient to submit for monitoring. Other monitoring activities
were performed. One contract was reported as a subaward on the preliminary SEFA.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entities must establish and
maintain effective internal control over the Federal award that provides reasonable assurance that the
non-Federal entities is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General
of the United States or the “Internal Control Integrated Framework”, issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.332e(1), in monitoring a subrecipient, a pass-through
entity must review financial and performance reports.
Cause: Inconsistent application of controls throughout the year and with different subrecipients and
entities resulted in poor documentation of control activities, and misclassification of a contract as a
subaward.
Questioned Cost: None.
Effect: Inconsistent application of controls can result in noncompliance due to errors or fraud not being
prevented or detected by employees. The Uniform Guidance requires pass-through entities to review
reports submitted by subrecipients, and the City was not able to substantiate compliance with this
requirement.