2022-005 WATERSMART GRANT - MATCHING Federal Program Information Funding agency: U.S. Department of Interior, Bureau of Reclamation Title: Reclamation States Emergency Drought Relief ALN: 15.514 Award Year: 2021 Questioned Costs: None Type of Finding: Material Weakness, Material Non-Compliance Condition The grant agreement contained a cost-sharing requirement that the $748,980 Federal share not be expended in advance of the Village?s $825,920 non-Federal share of allowable costs. It was expected that expenditure of Federal and non-Federal funds, based upon estimated cost share percentages, would occur concurrently. The Village was entitled to be reimbursed for costs incurred after July 1, 2020, but prior to the date of the agreement. The Village incurred $248,174 in such pre-award costs and other non-Federal share costs concurrent with the Federal share during fiscal year 2022. However, the entire Federal share of $748,980 was incurred and drawn down during fiscal year 2022, in violation of the above cost-sharing requirement. The Village has been awarded two grants for Special Appropriation Program funds from the New Mexico Environment Department, which are sufficient to meet the matching requirements, and have obligated all such funding to the grant project. Construction related to these funds has experienced delays and is still ongoing after fiscal year 2022 year-end and the end of the period of performance. Project closeout for these grants are expected to be completed soon, within the next quarter based on provided milestones. Criteria The Federal government may require the recipient to provide contributions to cover a portion of that program?s operations, and may stipulate in the grant agreement if this should be required to be performed proportionately throughout the grant period. A system of internal control needs to provide reasonable assurance that objectives of internal control over compliance requirements relating to compliance with the terms and conditions of Federal awards will be achieved. Effect The Village is not in compliance with federal grant matching requirements. As matching funds have only been obligated but not necessarily expended, it is possible that matching requirements may not ultimately be met at the end of the project, in which case a portion of federal funding may need to be returned. Cause Due to turnover within the Village?s finance department, the Village was unaware of the grant requirements. The Village lacks controls over compliance in this area.
2022-006 WATERSMART GRANT - REPORTING Federal Program Information Funding agency: U.S. Department of Interior, Bureau of Reclamation Title: Reclamation States Emergency Drought Relief ALN: 15.514 Award Year: 2021 Questioned Costs: None Type of Finding: Significant Deficiency, Other Non-Compliance Condition We noted the Village is not in compliance with requirements related to the reporting of grants. During our test work, we noted the following exceptions: ? The Village did not complete the recipient share section of the federal financial reports for 1 of 2 reports tested. ? The Village did not submit semi-annual performance progress reports (PPRs) timely for 1 of the 2 reports tested. Criteria According to ?200.302 Financial management of 2 CFR Part 200, the state?s and the other non-Federal entity?s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program specific terms and conditions. Further, the financial management system of each non-Federal entity must provide accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements. According to ?200.303 Internal controls of 2 CFR Part 200, 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. Effect The Village is not in compliance with federal reporting requirements. Cause The Village lacks established internal controls and procedures over financial grant management to ensure submitted reports are complete.
2022-005 WATERSMART GRANT - MATCHING Federal Program Information Funding agency: U.S. Department of Interior, Bureau of Reclamation Title: Reclamation States Emergency Drought Relief ALN: 15.514 Award Year: 2021 Questioned Costs: None Type of Finding: Material Weakness, Material Non-Compliance Condition The grant agreement contained a cost-sharing requirement that the $748,980 Federal share not be expended in advance of the Village?s $825,920 non-Federal share of allowable costs. It was expected that expenditure of Federal and non-Federal funds, based upon estimated cost share percentages, would occur concurrently. The Village was entitled to be reimbursed for costs incurred after July 1, 2020, but prior to the date of the agreement. The Village incurred $248,174 in such pre-award costs and other non-Federal share costs concurrent with the Federal share during fiscal year 2022. However, the entire Federal share of $748,980 was incurred and drawn down during fiscal year 2022, in violation of the above cost-sharing requirement. The Village has been awarded two grants for Special Appropriation Program funds from the New Mexico Environment Department, which are sufficient to meet the matching requirements, and have obligated all such funding to the grant project. Construction related to these funds has experienced delays and is still ongoing after fiscal year 2022 year-end and the end of the period of performance. Project closeout for these grants are expected to be completed soon, within the next quarter based on provided milestones. Criteria The Federal government may require the recipient to provide contributions to cover a portion of that program?s operations, and may stipulate in the grant agreement if this should be required to be performed proportionately throughout the grant period. A system of internal control needs to provide reasonable assurance that objectives of internal control over compliance requirements relating to compliance with the terms and conditions of Federal awards will be achieved. Effect The Village is not in compliance with federal grant matching requirements. As matching funds have only been obligated but not necessarily expended, it is possible that matching requirements may not ultimately be met at the end of the project, in which case a portion of federal funding may need to be returned. Cause Due to turnover within the Village?s finance department, the Village was unaware of the grant requirements. The Village lacks controls over compliance in this area.
2022-006 WATERSMART GRANT - REPORTING Federal Program Information Funding agency: U.S. Department of Interior, Bureau of Reclamation Title: Reclamation States Emergency Drought Relief ALN: 15.514 Award Year: 2021 Questioned Costs: None Type of Finding: Significant Deficiency, Other Non-Compliance Condition We noted the Village is not in compliance with requirements related to the reporting of grants. During our test work, we noted the following exceptions: ? The Village did not complete the recipient share section of the federal financial reports for 1 of 2 reports tested. ? The Village did not submit semi-annual performance progress reports (PPRs) timely for 1 of the 2 reports tested. Criteria According to ?200.302 Financial management of 2 CFR Part 200, the state?s and the other non-Federal entity?s financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program specific terms and conditions. Further, the financial management system of each non-Federal entity must provide accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements. According to ?200.303 Internal controls of 2 CFR Part 200, 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. Effect The Village is not in compliance with federal reporting requirements. Cause The Village lacks established internal controls and procedures over financial grant management to ensure submitted reports are complete.