AL No: 20.507
Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Cluster -
Direct Award
Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles.
Condition: The District’s internal controls over compliance requirements did not identify ineligible costs
applied to two separate Federal Transit Administration (FTA) grants as follows.
Section 5307 Grant Award CA-2020-173-01: The District overclaimed Sacramento fixed route
operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in
ineligible costs of $183,848 being charged to the program.
Questioned Costs: $183,548
Section 5307 Grant Award CA-2023-122-01: The District overclaimed Woodland fixed route
operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in
ineligible costs of $175,143 being charged to the program.
Questioned Costs: $175,143.
In addition to these ineligible costs, there were substantial changes to the Schedule of Expenditures of Federal
Awards (SEFA) and federal grant revenue reported in the general ledger (GL) during the course of the audit.
These changes and issues are as follows.
There was a total of $302,813 removed from the SEFA and GL for claims prepared for expenses
incurred after the period of performance end date specified in the grant for the relevant project and
therefore would have been ineligible if the claim was submitted to the grantor. These claims were
prepared for paratransit and microtransit operating assistance.
There was a total of $243,823 removed from the SEFA and GL for claims prepared for an FTA direct
program grant that is already past the end date of the period of performance and therefore would have
been ineligible if the claim was submitted to the grantor. These claims were drafted for Woodland
microtransit operating assistance. There was a total of $354,429 added to the SEFA for federal grant revenues recorded in the GL but not
initially included on the SEFA. These claims are for the Yolo County Bike and Pedestrian Trail
Network Planning Project and the Yolo 80 Managed Lanes Tolling Advance Planning project.
There was a total of $1,106,389 of expenses reported on the SEFA but not recognized as revenue in the
GL for amounts previously overclaimed for ineligible expenses but reclaimed and approved for
eligible expenses in the current period.
Criteria: 2 CFR Part 200, Subpart E (Uniform Guidance) Section 200.303 states that “The nonfederal entity
must: (a) 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.”
Cause:. Grant management procedures are not documented and a schedule of all available grants was not
prepared by the District to use when reconciling expenses for inclusion on the SEFA and accruing grant
revenue. The errors on the SEFA were not captured by the District’s review procedures due to recent staff
turnover, lack of documented procedures on grant management, and/or lack of training.
Effect: Expenses were omitted from the SEFA that should have been included and other expenses were
included on the SEFA that were not eligible. The SEFA had to be revised for multiple grants over the course of
the audit, which delayed the audit testing and major program determination process.
Context: The number of grants has increased since the pandemic due to new pandemic related grants becoming
available that delayed the use of the District’s regular federal grants. This caused grants to be combined by
grantors with different allowable expenses, areas of service, and periods of performance and caused grants to be
extended, causing complexity. The District confirmed that there will be no other federal grants used for
reimbursement of the expenses that were removed from the SEFA during the audit.
Recommendation: We recommend the District develop written procedures to allocate expenses to routes and
purposes under federal grants that document the timing of the preparation and review of the allocation schedule.
A summary tab should be added to the allocation schedule to reconcile amounts for each route/purpose to total
operating expenses, preventive maintenance, insurance, communications and other expenses allocated to the
population of expenses in the general ledger. We also recommend the District develop a schedule to summarize
all approved and pending grants that includes the amounts available under each grant, each route/purpose within
each grant, periods of performance for each amount available, the last date to submit invoices, and amounts
claimed and still available for each grant by route/purpose. The District should re-evaluate budgets if changes or
delays occur to federal grants and ensure a new federal or local funding source is identified and claimed for the
expenses. The SEFA should be prepared after expenses are reconciled to the GL at the invoice level by
route/purpose and the allocation schedule is thoroughly reviewed. The SEFA should be reviewed by a
knowledgeable member of management to ensure completeness and accuracy. We also recommend the District
claim expenses more quickly to allow the granting agency time to review and approve the claims before the
audit begins. We recommend the District reconcile expenses within 30 days of quarter end and prepare claims
within 45 days of quarter end. If the District is unsure about the period of performance dates or other restrictions
on a grant, staff should contact the granting agency for clarification. Finally, we recommend the District discuss
the overclaimed amounts of $183,548 and $175,143 described above with the FTA to determine whether these
overclaimed funds must be returned or whether they may be used to claim future expenses.
View of Responsible Officials and Planned Corrective Action: Management’s response and planned
corrective action is included at the Corrective Action Plan end of this report.
AL No: 20.507
Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Cluster -
Direct Award
Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles.
Condition: The District’s internal controls over compliance requirements did not identify ineligible costs
applied to two separate Federal Transit Administration (FTA) grants as follows.
Section 5307 Grant Award CA-2020-173-01: The District overclaimed Sacramento fixed route
operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in
ineligible costs of $183,848 being charged to the program.
Questioned Costs: $183,548
Section 5307 Grant Award CA-2023-122-01: The District overclaimed Woodland fixed route
operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in
ineligible costs of $175,143 being charged to the program.
Questioned Costs: $175,143.
In addition to these ineligible costs, there were substantial changes to the Schedule of Expenditures of Federal
Awards (SEFA) and federal grant revenue reported in the general ledger (GL) during the course of the audit.
These changes and issues are as follows.
There was a total of $302,813 removed from the SEFA and GL for claims prepared for expenses
incurred after the period of performance end date specified in the grant for the relevant project and
therefore would have been ineligible if the claim was submitted to the grantor. These claims were
prepared for paratransit and microtransit operating assistance.
There was a total of $243,823 removed from the SEFA and GL for claims prepared for an FTA direct
program grant that is already past the end date of the period of performance and therefore would have
been ineligible if the claim was submitted to the grantor. These claims were drafted for Woodland
microtransit operating assistance. There was a total of $354,429 added to the SEFA for federal grant revenues recorded in the GL but not
initially included on the SEFA. These claims are for the Yolo County Bike and Pedestrian Trail
Network Planning Project and the Yolo 80 Managed Lanes Tolling Advance Planning project.
There was a total of $1,106,389 of expenses reported on the SEFA but not recognized as revenue in the
GL for amounts previously overclaimed for ineligible expenses but reclaimed and approved for
eligible expenses in the current period.
Criteria: 2 CFR Part 200, Subpart E (Uniform Guidance) Section 200.303 states that “The nonfederal entity
must: (a) 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.”
Cause:. Grant management procedures are not documented and a schedule of all available grants was not
prepared by the District to use when reconciling expenses for inclusion on the SEFA and accruing grant
revenue. The errors on the SEFA were not captured by the District’s review procedures due to recent staff
turnover, lack of documented procedures on grant management, and/or lack of training.
Effect: Expenses were omitted from the SEFA that should have been included and other expenses were
included on the SEFA that were not eligible. The SEFA had to be revised for multiple grants over the course of
the audit, which delayed the audit testing and major program determination process.
Context: The number of grants has increased since the pandemic due to new pandemic related grants becoming
available that delayed the use of the District’s regular federal grants. This caused grants to be combined by
grantors with different allowable expenses, areas of service, and periods of performance and caused grants to be
extended, causing complexity. The District confirmed that there will be no other federal grants used for
reimbursement of the expenses that were removed from the SEFA during the audit.
Recommendation: We recommend the District develop written procedures to allocate expenses to routes and
purposes under federal grants that document the timing of the preparation and review of the allocation schedule.
A summary tab should be added to the allocation schedule to reconcile amounts for each route/purpose to total
operating expenses, preventive maintenance, insurance, communications and other expenses allocated to the
population of expenses in the general ledger. We also recommend the District develop a schedule to summarize
all approved and pending grants that includes the amounts available under each grant, each route/purpose within
each grant, periods of performance for each amount available, the last date to submit invoices, and amounts
claimed and still available for each grant by route/purpose. The District should re-evaluate budgets if changes or
delays occur to federal grants and ensure a new federal or local funding source is identified and claimed for the
expenses. The SEFA should be prepared after expenses are reconciled to the GL at the invoice level by
route/purpose and the allocation schedule is thoroughly reviewed. The SEFA should be reviewed by a
knowledgeable member of management to ensure completeness and accuracy. We also recommend the District
claim expenses more quickly to allow the granting agency time to review and approve the claims before the
audit begins. We recommend the District reconcile expenses within 30 days of quarter end and prepare claims
within 45 days of quarter end. If the District is unsure about the period of performance dates or other restrictions
on a grant, staff should contact the granting agency for clarification. Finally, we recommend the District discuss
the overclaimed amounts of $183,548 and $175,143 described above with the FTA to determine whether these
overclaimed funds must be returned or whether they may be used to claim future expenses.
View of Responsible Officials and Planned Corrective Action: Management’s response and planned
corrective action is included at the Corrective Action Plan end of this report.
AL No: 20.507
Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Cluster -
Direct Award
Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles.
Condition: The District’s internal controls over compliance requirements did not identify ineligible costs
applied to two separate Federal Transit Administration (FTA) grants as follows.
Section 5307 Grant Award CA-2020-173-01: The District overclaimed Sacramento fixed route
operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in
ineligible costs of $183,848 being charged to the program.
Questioned Costs: $183,548
Section 5307 Grant Award CA-2023-122-01: The District overclaimed Woodland fixed route
operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in
ineligible costs of $175,143 being charged to the program.
Questioned Costs: $175,143.
In addition to these ineligible costs, there were substantial changes to the Schedule of Expenditures of Federal
Awards (SEFA) and federal grant revenue reported in the general ledger (GL) during the course of the audit.
These changes and issues are as follows.
There was a total of $302,813 removed from the SEFA and GL for claims prepared for expenses
incurred after the period of performance end date specified in the grant for the relevant project and
therefore would have been ineligible if the claim was submitted to the grantor. These claims were
prepared for paratransit and microtransit operating assistance.
There was a total of $243,823 removed from the SEFA and GL for claims prepared for an FTA direct
program grant that is already past the end date of the period of performance and therefore would have
been ineligible if the claim was submitted to the grantor. These claims were drafted for Woodland
microtransit operating assistance. There was a total of $354,429 added to the SEFA for federal grant revenues recorded in the GL but not
initially included on the SEFA. These claims are for the Yolo County Bike and Pedestrian Trail
Network Planning Project and the Yolo 80 Managed Lanes Tolling Advance Planning project.
There was a total of $1,106,389 of expenses reported on the SEFA but not recognized as revenue in the
GL for amounts previously overclaimed for ineligible expenses but reclaimed and approved for
eligible expenses in the current period.
Criteria: 2 CFR Part 200, Subpart E (Uniform Guidance) Section 200.303 states that “The nonfederal entity
must: (a) 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.”
Cause:. Grant management procedures are not documented and a schedule of all available grants was not
prepared by the District to use when reconciling expenses for inclusion on the SEFA and accruing grant
revenue. The errors on the SEFA were not captured by the District’s review procedures due to recent staff
turnover, lack of documented procedures on grant management, and/or lack of training.
Effect: Expenses were omitted from the SEFA that should have been included and other expenses were
included on the SEFA that were not eligible. The SEFA had to be revised for multiple grants over the course of
the audit, which delayed the audit testing and major program determination process.
Context: The number of grants has increased since the pandemic due to new pandemic related grants becoming
available that delayed the use of the District’s regular federal grants. This caused grants to be combined by
grantors with different allowable expenses, areas of service, and periods of performance and caused grants to be
extended, causing complexity. The District confirmed that there will be no other federal grants used for
reimbursement of the expenses that were removed from the SEFA during the audit.
Recommendation: We recommend the District develop written procedures to allocate expenses to routes and
purposes under federal grants that document the timing of the preparation and review of the allocation schedule.
A summary tab should be added to the allocation schedule to reconcile amounts for each route/purpose to total
operating expenses, preventive maintenance, insurance, communications and other expenses allocated to the
population of expenses in the general ledger. We also recommend the District develop a schedule to summarize
all approved and pending grants that includes the amounts available under each grant, each route/purpose within
each grant, periods of performance for each amount available, the last date to submit invoices, and amounts
claimed and still available for each grant by route/purpose. The District should re-evaluate budgets if changes or
delays occur to federal grants and ensure a new federal or local funding source is identified and claimed for the
expenses. The SEFA should be prepared after expenses are reconciled to the GL at the invoice level by
route/purpose and the allocation schedule is thoroughly reviewed. The SEFA should be reviewed by a
knowledgeable member of management to ensure completeness and accuracy. We also recommend the District
claim expenses more quickly to allow the granting agency time to review and approve the claims before the
audit begins. We recommend the District reconcile expenses within 30 days of quarter end and prepare claims
within 45 days of quarter end. If the District is unsure about the period of performance dates or other restrictions
on a grant, staff should contact the granting agency for clarification. Finally, we recommend the District discuss
the overclaimed amounts of $183,548 and $175,143 described above with the FTA to determine whether these
overclaimed funds must be returned or whether they may be used to claim future expenses.
View of Responsible Officials and Planned Corrective Action: Management’s response and planned
corrective action is included at the Corrective Action Plan end of this report.
AL No: 20.507
Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Cluster -
Direct Award
Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles.
Condition: The District’s internal controls over compliance requirements did not identify ineligible costs
applied to two separate Federal Transit Administration (FTA) grants as follows.
Section 5307 Grant Award CA-2020-173-01: The District overclaimed Sacramento fixed route
operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in
ineligible costs of $183,848 being charged to the program.
Questioned Costs: $183,548
Section 5307 Grant Award CA-2023-122-01: The District overclaimed Woodland fixed route
operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in
ineligible costs of $175,143 being charged to the program.
Questioned Costs: $175,143.
In addition to these ineligible costs, there were substantial changes to the Schedule of Expenditures of Federal
Awards (SEFA) and federal grant revenue reported in the general ledger (GL) during the course of the audit.
These changes and issues are as follows.
There was a total of $302,813 removed from the SEFA and GL for claims prepared for expenses
incurred after the period of performance end date specified in the grant for the relevant project and
therefore would have been ineligible if the claim was submitted to the grantor. These claims were
prepared for paratransit and microtransit operating assistance.
There was a total of $243,823 removed from the SEFA and GL for claims prepared for an FTA direct
program grant that is already past the end date of the period of performance and therefore would have
been ineligible if the claim was submitted to the grantor. These claims were drafted for Woodland
microtransit operating assistance. There was a total of $354,429 added to the SEFA for federal grant revenues recorded in the GL but not
initially included on the SEFA. These claims are for the Yolo County Bike and Pedestrian Trail
Network Planning Project and the Yolo 80 Managed Lanes Tolling Advance Planning project.
There was a total of $1,106,389 of expenses reported on the SEFA but not recognized as revenue in the
GL for amounts previously overclaimed for ineligible expenses but reclaimed and approved for
eligible expenses in the current period.
Criteria: 2 CFR Part 200, Subpart E (Uniform Guidance) Section 200.303 states that “The nonfederal entity
must: (a) 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.”
Cause:. Grant management procedures are not documented and a schedule of all available grants was not
prepared by the District to use when reconciling expenses for inclusion on the SEFA and accruing grant
revenue. The errors on the SEFA were not captured by the District’s review procedures due to recent staff
turnover, lack of documented procedures on grant management, and/or lack of training.
Effect: Expenses were omitted from the SEFA that should have been included and other expenses were
included on the SEFA that were not eligible. The SEFA had to be revised for multiple grants over the course of
the audit, which delayed the audit testing and major program determination process.
Context: The number of grants has increased since the pandemic due to new pandemic related grants becoming
available that delayed the use of the District’s regular federal grants. This caused grants to be combined by
grantors with different allowable expenses, areas of service, and periods of performance and caused grants to be
extended, causing complexity. The District confirmed that there will be no other federal grants used for
reimbursement of the expenses that were removed from the SEFA during the audit.
Recommendation: We recommend the District develop written procedures to allocate expenses to routes and
purposes under federal grants that document the timing of the preparation and review of the allocation schedule.
A summary tab should be added to the allocation schedule to reconcile amounts for each route/purpose to total
operating expenses, preventive maintenance, insurance, communications and other expenses allocated to the
population of expenses in the general ledger. We also recommend the District develop a schedule to summarize
all approved and pending grants that includes the amounts available under each grant, each route/purpose within
each grant, periods of performance for each amount available, the last date to submit invoices, and amounts
claimed and still available for each grant by route/purpose. The District should re-evaluate budgets if changes or
delays occur to federal grants and ensure a new federal or local funding source is identified and claimed for the
expenses. The SEFA should be prepared after expenses are reconciled to the GL at the invoice level by
route/purpose and the allocation schedule is thoroughly reviewed. The SEFA should be reviewed by a
knowledgeable member of management to ensure completeness and accuracy. We also recommend the District
claim expenses more quickly to allow the granting agency time to review and approve the claims before the
audit begins. We recommend the District reconcile expenses within 30 days of quarter end and prepare claims
within 45 days of quarter end. If the District is unsure about the period of performance dates or other restrictions
on a grant, staff should contact the granting agency for clarification. Finally, we recommend the District discuss
the overclaimed amounts of $183,548 and $175,143 described above with the FTA to determine whether these
overclaimed funds must be returned or whether they may be used to claim future expenses.
View of Responsible Officials and Planned Corrective Action: Management’s response and planned
corrective action is included at the Corrective Action Plan end of this report.
AL No: 20.507
Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Cluster -
Direct Award. Compliance Requirement: Procurement, Suspension and Debarment.
Condition: The District was unable to provide documentation of the evaluation each proposal received and
reason for selection of the winning bid for the procurement of a consulting firm to conduct the site selection
study for the Woodland Transit Center project. The District also did not include a Debarment and Suspension
clause in the request for proposal or contract and did not require a certificate confirming the contractor was not
debarred in the final agreement. The District was not able to find records of the District verifying that the
awarded consulting firm is not on the governmentwide exclusions in the System for Award Management
(SAM).
Criteria: 2 CFR Part 200 Subpart E (Uniform Guidance) states the following:
Section 200.318(a) states that “The non-federal entity must have and use documented procurement
procedures, consistent with State, local, and tribal laws and regulations and the standards of this
section, for the acquisition of property or service required under a Federal award or subaward. The
non-Federal entity’s documented procurement procedures must conform to the procurement standards
identified in Sections 200.317 through 200.327.”
Section 200.318(i) states that “The non-Federal entity must maintain records sufficient to detail the
history of procurement. These records will include, but are not necessarily limited to, the following:
Rationale for the method of procurement, selection of contract type, contractor selection or rejection,
and the basis for the contract price.”
Section 200.327 states that “The recipient's or subrecipient's contracts must contain the applicable
provisions described in Appendix II of this part.” Appendix II(H) includes “Debarment and Suspension
(Executive Orders 12549 and 12689)—A contract award (see 2 CFR 180.220) must not be made to
parties listed on the governmentwide exclusions in the System for Award Management (SAM), in
accordance with the OMB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR
part 1986 Comp., p. 189) and 12689 (3 CFR part 1989 Comp., p. 235), “Debarment and Suspension.”
SAM Exclusions contains the names of parties debarred, suspended, or otherwise excluded by
agencies, as well as parties declared ineligible under statutory or regulatory authority other than
Executive Order 12549.”
Cause: The current staff was not able to find procurement documentation prepared before they were hired.
Effect: The District was unable to provide evidence that it was in compliance with the Uniform Guidance
requirement to maintain documentation of procurement procedures.
Context: The original procurement for the consulting firm for the Woodland Transit Project was performed in
late December 2017 and awarded in January 2018 and then extended during 2024. This procurement precedes
the current staff. It was verified the contractor selected was not debarred during the 2024 single audit.
Recommendation: We recommend the District establish a procurement folder on its server with subfolders for
each individual procurement where documentation of each procurement is maintained, including advertising of
the procurement, requests for proposals, proposals received, analysis of reasons for selecting the winning bid,
executed contract, certifications by contractor if not part of the proposal or executed contract, management
report to board recommending which bid should be approved, board resolution approving the winning bid and
for contracts under $250,000 a memo or form documenting bids received and reason for selecting the bid,
including reasons for not selecting the lowest bid if applicable. We also recommend training be provided to
staff that work on procurements of the requirements under Uniform Guidance Section 2 CFR 200.318 to
200.326.
View of Responsible Officials and Planned Corrective Action: Management’s response and planned
corrective action is included at the Corrective Action Plan end of this report.
AL No: 20.507
Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Cluster -
Direct Award
Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles.
Condition: The District’s internal controls over compliance requirements did not identify ineligible costs
applied to two separate Federal Transit Administration (FTA) grants as follows.
Section 5307 Grant Award CA-2020-173-01: The District overclaimed Sacramento fixed route
operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in
ineligible costs of $183,848 being charged to the program.
Questioned Costs: $183,548
Section 5307 Grant Award CA-2023-122-01: The District overclaimed Woodland fixed route
operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in
ineligible costs of $175,143 being charged to the program.
Questioned Costs: $175,143.
In addition to these ineligible costs, there were substantial changes to the Schedule of Expenditures of Federal
Awards (SEFA) and federal grant revenue reported in the general ledger (GL) during the course of the audit.
These changes and issues are as follows.
There was a total of $302,813 removed from the SEFA and GL for claims prepared for expenses
incurred after the period of performance end date specified in the grant for the relevant project and
therefore would have been ineligible if the claim was submitted to the grantor. These claims were
prepared for paratransit and microtransit operating assistance.
There was a total of $243,823 removed from the SEFA and GL for claims prepared for an FTA direct
program grant that is already past the end date of the period of performance and therefore would have
been ineligible if the claim was submitted to the grantor. These claims were drafted for Woodland
microtransit operating assistance. There was a total of $354,429 added to the SEFA for federal grant revenues recorded in the GL but not
initially included on the SEFA. These claims are for the Yolo County Bike and Pedestrian Trail
Network Planning Project and the Yolo 80 Managed Lanes Tolling Advance Planning project.
There was a total of $1,106,389 of expenses reported on the SEFA but not recognized as revenue in the
GL for amounts previously overclaimed for ineligible expenses but reclaimed and approved for
eligible expenses in the current period.
Criteria: 2 CFR Part 200, Subpart E (Uniform Guidance) Section 200.303 states that “The nonfederal entity
must: (a) 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.”
Cause:. Grant management procedures are not documented and a schedule of all available grants was not
prepared by the District to use when reconciling expenses for inclusion on the SEFA and accruing grant
revenue. The errors on the SEFA were not captured by the District’s review procedures due to recent staff
turnover, lack of documented procedures on grant management, and/or lack of training.
Effect: Expenses were omitted from the SEFA that should have been included and other expenses were
included on the SEFA that were not eligible. The SEFA had to be revised for multiple grants over the course of
the audit, which delayed the audit testing and major program determination process.
Context: The number of grants has increased since the pandemic due to new pandemic related grants becoming
available that delayed the use of the District’s regular federal grants. This caused grants to be combined by
grantors with different allowable expenses, areas of service, and periods of performance and caused grants to be
extended, causing complexity. The District confirmed that there will be no other federal grants used for
reimbursement of the expenses that were removed from the SEFA during the audit.
Recommendation: We recommend the District develop written procedures to allocate expenses to routes and
purposes under federal grants that document the timing of the preparation and review of the allocation schedule.
A summary tab should be added to the allocation schedule to reconcile amounts for each route/purpose to total
operating expenses, preventive maintenance, insurance, communications and other expenses allocated to the
population of expenses in the general ledger. We also recommend the District develop a schedule to summarize
all approved and pending grants that includes the amounts available under each grant, each route/purpose within
each grant, periods of performance for each amount available, the last date to submit invoices, and amounts
claimed and still available for each grant by route/purpose. The District should re-evaluate budgets if changes or
delays occur to federal grants and ensure a new federal or local funding source is identified and claimed for the
expenses. The SEFA should be prepared after expenses are reconciled to the GL at the invoice level by
route/purpose and the allocation schedule is thoroughly reviewed. The SEFA should be reviewed by a
knowledgeable member of management to ensure completeness and accuracy. We also recommend the District
claim expenses more quickly to allow the granting agency time to review and approve the claims before the
audit begins. We recommend the District reconcile expenses within 30 days of quarter end and prepare claims
within 45 days of quarter end. If the District is unsure about the period of performance dates or other restrictions
on a grant, staff should contact the granting agency for clarification. Finally, we recommend the District discuss
the overclaimed amounts of $183,548 and $175,143 described above with the FTA to determine whether these
overclaimed funds must be returned or whether they may be used to claim future expenses.
View of Responsible Officials and Planned Corrective Action: Management’s response and planned
corrective action is included at the Corrective Action Plan end of this report.
AL No: 20.507
Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Cluster -
Direct Award
Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles.
Condition: The District’s internal controls over compliance requirements did not identify ineligible costs
applied to two separate Federal Transit Administration (FTA) grants as follows.
Section 5307 Grant Award CA-2020-173-01: The District overclaimed Sacramento fixed route
operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in
ineligible costs of $183,848 being charged to the program.
Questioned Costs: $183,548
Section 5307 Grant Award CA-2023-122-01: The District overclaimed Woodland fixed route
operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in
ineligible costs of $175,143 being charged to the program.
Questioned Costs: $175,143.
In addition to these ineligible costs, there were substantial changes to the Schedule of Expenditures of Federal
Awards (SEFA) and federal grant revenue reported in the general ledger (GL) during the course of the audit.
These changes and issues are as follows.
There was a total of $302,813 removed from the SEFA and GL for claims prepared for expenses
incurred after the period of performance end date specified in the grant for the relevant project and
therefore would have been ineligible if the claim was submitted to the grantor. These claims were
prepared for paratransit and microtransit operating assistance.
There was a total of $243,823 removed from the SEFA and GL for claims prepared for an FTA direct
program grant that is already past the end date of the period of performance and therefore would have
been ineligible if the claim was submitted to the grantor. These claims were drafted for Woodland
microtransit operating assistance. There was a total of $354,429 added to the SEFA for federal grant revenues recorded in the GL but not
initially included on the SEFA. These claims are for the Yolo County Bike and Pedestrian Trail
Network Planning Project and the Yolo 80 Managed Lanes Tolling Advance Planning project.
There was a total of $1,106,389 of expenses reported on the SEFA but not recognized as revenue in the
GL for amounts previously overclaimed for ineligible expenses but reclaimed and approved for
eligible expenses in the current period.
Criteria: 2 CFR Part 200, Subpart E (Uniform Guidance) Section 200.303 states that “The nonfederal entity
must: (a) 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.”
Cause:. Grant management procedures are not documented and a schedule of all available grants was not
prepared by the District to use when reconciling expenses for inclusion on the SEFA and accruing grant
revenue. The errors on the SEFA were not captured by the District’s review procedures due to recent staff
turnover, lack of documented procedures on grant management, and/or lack of training.
Effect: Expenses were omitted from the SEFA that should have been included and other expenses were
included on the SEFA that were not eligible. The SEFA had to be revised for multiple grants over the course of
the audit, which delayed the audit testing and major program determination process.
Context: The number of grants has increased since the pandemic due to new pandemic related grants becoming
available that delayed the use of the District’s regular federal grants. This caused grants to be combined by
grantors with different allowable expenses, areas of service, and periods of performance and caused grants to be
extended, causing complexity. The District confirmed that there will be no other federal grants used for
reimbursement of the expenses that were removed from the SEFA during the audit.
Recommendation: We recommend the District develop written procedures to allocate expenses to routes and
purposes under federal grants that document the timing of the preparation and review of the allocation schedule.
A summary tab should be added to the allocation schedule to reconcile amounts for each route/purpose to total
operating expenses, preventive maintenance, insurance, communications and other expenses allocated to the
population of expenses in the general ledger. We also recommend the District develop a schedule to summarize
all approved and pending grants that includes the amounts available under each grant, each route/purpose within
each grant, periods of performance for each amount available, the last date to submit invoices, and amounts
claimed and still available for each grant by route/purpose. The District should re-evaluate budgets if changes or
delays occur to federal grants and ensure a new federal or local funding source is identified and claimed for the
expenses. The SEFA should be prepared after expenses are reconciled to the GL at the invoice level by
route/purpose and the allocation schedule is thoroughly reviewed. The SEFA should be reviewed by a
knowledgeable member of management to ensure completeness and accuracy. We also recommend the District
claim expenses more quickly to allow the granting agency time to review and approve the claims before the
audit begins. We recommend the District reconcile expenses within 30 days of quarter end and prepare claims
within 45 days of quarter end. If the District is unsure about the period of performance dates or other restrictions
on a grant, staff should contact the granting agency for clarification. Finally, we recommend the District discuss
the overclaimed amounts of $183,548 and $175,143 described above with the FTA to determine whether these
overclaimed funds must be returned or whether they may be used to claim future expenses.
View of Responsible Officials and Planned Corrective Action: Management’s response and planned
corrective action is included at the Corrective Action Plan end of this report.
AL No: 20.507
Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Cluster -
Direct Award
Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles.
Condition: The District’s internal controls over compliance requirements did not identify ineligible costs
applied to two separate Federal Transit Administration (FTA) grants as follows.
Section 5307 Grant Award CA-2020-173-01: The District overclaimed Sacramento fixed route
operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in
ineligible costs of $183,848 being charged to the program.
Questioned Costs: $183,548
Section 5307 Grant Award CA-2023-122-01: The District overclaimed Woodland fixed route
operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in
ineligible costs of $175,143 being charged to the program.
Questioned Costs: $175,143.
In addition to these ineligible costs, there were substantial changes to the Schedule of Expenditures of Federal
Awards (SEFA) and federal grant revenue reported in the general ledger (GL) during the course of the audit.
These changes and issues are as follows.
There was a total of $302,813 removed from the SEFA and GL for claims prepared for expenses
incurred after the period of performance end date specified in the grant for the relevant project and
therefore would have been ineligible if the claim was submitted to the grantor. These claims were
prepared for paratransit and microtransit operating assistance.
There was a total of $243,823 removed from the SEFA and GL for claims prepared for an FTA direct
program grant that is already past the end date of the period of performance and therefore would have
been ineligible if the claim was submitted to the grantor. These claims were drafted for Woodland
microtransit operating assistance. There was a total of $354,429 added to the SEFA for federal grant revenues recorded in the GL but not
initially included on the SEFA. These claims are for the Yolo County Bike and Pedestrian Trail
Network Planning Project and the Yolo 80 Managed Lanes Tolling Advance Planning project.
There was a total of $1,106,389 of expenses reported on the SEFA but not recognized as revenue in the
GL for amounts previously overclaimed for ineligible expenses but reclaimed and approved for
eligible expenses in the current period.
Criteria: 2 CFR Part 200, Subpart E (Uniform Guidance) Section 200.303 states that “The nonfederal entity
must: (a) 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.”
Cause:. Grant management procedures are not documented and a schedule of all available grants was not
prepared by the District to use when reconciling expenses for inclusion on the SEFA and accruing grant
revenue. The errors on the SEFA were not captured by the District’s review procedures due to recent staff
turnover, lack of documented procedures on grant management, and/or lack of training.
Effect: Expenses were omitted from the SEFA that should have been included and other expenses were
included on the SEFA that were not eligible. The SEFA had to be revised for multiple grants over the course of
the audit, which delayed the audit testing and major program determination process.
Context: The number of grants has increased since the pandemic due to new pandemic related grants becoming
available that delayed the use of the District’s regular federal grants. This caused grants to be combined by
grantors with different allowable expenses, areas of service, and periods of performance and caused grants to be
extended, causing complexity. The District confirmed that there will be no other federal grants used for
reimbursement of the expenses that were removed from the SEFA during the audit.
Recommendation: We recommend the District develop written procedures to allocate expenses to routes and
purposes under federal grants that document the timing of the preparation and review of the allocation schedule.
A summary tab should be added to the allocation schedule to reconcile amounts for each route/purpose to total
operating expenses, preventive maintenance, insurance, communications and other expenses allocated to the
population of expenses in the general ledger. We also recommend the District develop a schedule to summarize
all approved and pending grants that includes the amounts available under each grant, each route/purpose within
each grant, periods of performance for each amount available, the last date to submit invoices, and amounts
claimed and still available for each grant by route/purpose. The District should re-evaluate budgets if changes or
delays occur to federal grants and ensure a new federal or local funding source is identified and claimed for the
expenses. The SEFA should be prepared after expenses are reconciled to the GL at the invoice level by
route/purpose and the allocation schedule is thoroughly reviewed. The SEFA should be reviewed by a
knowledgeable member of management to ensure completeness and accuracy. We also recommend the District
claim expenses more quickly to allow the granting agency time to review and approve the claims before the
audit begins. We recommend the District reconcile expenses within 30 days of quarter end and prepare claims
within 45 days of quarter end. If the District is unsure about the period of performance dates or other restrictions
on a grant, staff should contact the granting agency for clarification. Finally, we recommend the District discuss
the overclaimed amounts of $183,548 and $175,143 described above with the FTA to determine whether these
overclaimed funds must be returned or whether they may be used to claim future expenses.
View of Responsible Officials and Planned Corrective Action: Management’s response and planned
corrective action is included at the Corrective Action Plan end of this report.
AL No: 20.507
Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Cluster -
Direct Award
Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles.
Condition: The District’s internal controls over compliance requirements did not identify ineligible costs
applied to two separate Federal Transit Administration (FTA) grants as follows.
Section 5307 Grant Award CA-2020-173-01: The District overclaimed Sacramento fixed route
operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in
ineligible costs of $183,848 being charged to the program.
Questioned Costs: $183,548
Section 5307 Grant Award CA-2023-122-01: The District overclaimed Woodland fixed route
operating expenses beyond the amount apportioned for these routes in the grant agreement, resulting in
ineligible costs of $175,143 being charged to the program.
Questioned Costs: $175,143.
In addition to these ineligible costs, there were substantial changes to the Schedule of Expenditures of Federal
Awards (SEFA) and federal grant revenue reported in the general ledger (GL) during the course of the audit.
These changes and issues are as follows.
There was a total of $302,813 removed from the SEFA and GL for claims prepared for expenses
incurred after the period of performance end date specified in the grant for the relevant project and
therefore would have been ineligible if the claim was submitted to the grantor. These claims were
prepared for paratransit and microtransit operating assistance.
There was a total of $243,823 removed from the SEFA and GL for claims prepared for an FTA direct
program grant that is already past the end date of the period of performance and therefore would have
been ineligible if the claim was submitted to the grantor. These claims were drafted for Woodland
microtransit operating assistance. There was a total of $354,429 added to the SEFA for federal grant revenues recorded in the GL but not
initially included on the SEFA. These claims are for the Yolo County Bike and Pedestrian Trail
Network Planning Project and the Yolo 80 Managed Lanes Tolling Advance Planning project.
There was a total of $1,106,389 of expenses reported on the SEFA but not recognized as revenue in the
GL for amounts previously overclaimed for ineligible expenses but reclaimed and approved for
eligible expenses in the current period.
Criteria: 2 CFR Part 200, Subpart E (Uniform Guidance) Section 200.303 states that “The nonfederal entity
must: (a) 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.”
Cause:. Grant management procedures are not documented and a schedule of all available grants was not
prepared by the District to use when reconciling expenses for inclusion on the SEFA and accruing grant
revenue. The errors on the SEFA were not captured by the District’s review procedures due to recent staff
turnover, lack of documented procedures on grant management, and/or lack of training.
Effect: Expenses were omitted from the SEFA that should have been included and other expenses were
included on the SEFA that were not eligible. The SEFA had to be revised for multiple grants over the course of
the audit, which delayed the audit testing and major program determination process.
Context: The number of grants has increased since the pandemic due to new pandemic related grants becoming
available that delayed the use of the District’s regular federal grants. This caused grants to be combined by
grantors with different allowable expenses, areas of service, and periods of performance and caused grants to be
extended, causing complexity. The District confirmed that there will be no other federal grants used for
reimbursement of the expenses that were removed from the SEFA during the audit.
Recommendation: We recommend the District develop written procedures to allocate expenses to routes and
purposes under federal grants that document the timing of the preparation and review of the allocation schedule.
A summary tab should be added to the allocation schedule to reconcile amounts for each route/purpose to total
operating expenses, preventive maintenance, insurance, communications and other expenses allocated to the
population of expenses in the general ledger. We also recommend the District develop a schedule to summarize
all approved and pending grants that includes the amounts available under each grant, each route/purpose within
each grant, periods of performance for each amount available, the last date to submit invoices, and amounts
claimed and still available for each grant by route/purpose. The District should re-evaluate budgets if changes or
delays occur to federal grants and ensure a new federal or local funding source is identified and claimed for the
expenses. The SEFA should be prepared after expenses are reconciled to the GL at the invoice level by
route/purpose and the allocation schedule is thoroughly reviewed. The SEFA should be reviewed by a
knowledgeable member of management to ensure completeness and accuracy. We also recommend the District
claim expenses more quickly to allow the granting agency time to review and approve the claims before the
audit begins. We recommend the District reconcile expenses within 30 days of quarter end and prepare claims
within 45 days of quarter end. If the District is unsure about the period of performance dates or other restrictions
on a grant, staff should contact the granting agency for clarification. Finally, we recommend the District discuss
the overclaimed amounts of $183,548 and $175,143 described above with the FTA to determine whether these
overclaimed funds must be returned or whether they may be used to claim future expenses.
View of Responsible Officials and Planned Corrective Action: Management’s response and planned
corrective action is included at the Corrective Action Plan end of this report.
AL No: 20.507
Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Cluster -
Direct Award. Compliance Requirement: Procurement, Suspension and Debarment.
Condition: The District was unable to provide documentation of the evaluation each proposal received and
reason for selection of the winning bid for the procurement of a consulting firm to conduct the site selection
study for the Woodland Transit Center project. The District also did not include a Debarment and Suspension
clause in the request for proposal or contract and did not require a certificate confirming the contractor was not
debarred in the final agreement. The District was not able to find records of the District verifying that the
awarded consulting firm is not on the governmentwide exclusions in the System for Award Management
(SAM).
Criteria: 2 CFR Part 200 Subpart E (Uniform Guidance) states the following:
Section 200.318(a) states that “The non-federal entity must have and use documented procurement
procedures, consistent with State, local, and tribal laws and regulations and the standards of this
section, for the acquisition of property or service required under a Federal award or subaward. The
non-Federal entity’s documented procurement procedures must conform to the procurement standards
identified in Sections 200.317 through 200.327.”
Section 200.318(i) states that “The non-Federal entity must maintain records sufficient to detail the
history of procurement. These records will include, but are not necessarily limited to, the following:
Rationale for the method of procurement, selection of contract type, contractor selection or rejection,
and the basis for the contract price.”
Section 200.327 states that “The recipient's or subrecipient's contracts must contain the applicable
provisions described in Appendix II of this part.” Appendix II(H) includes “Debarment and Suspension
(Executive Orders 12549 and 12689)—A contract award (see 2 CFR 180.220) must not be made to
parties listed on the governmentwide exclusions in the System for Award Management (SAM), in
accordance with the OMB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR
part 1986 Comp., p. 189) and 12689 (3 CFR part 1989 Comp., p. 235), “Debarment and Suspension.”
SAM Exclusions contains the names of parties debarred, suspended, or otherwise excluded by
agencies, as well as parties declared ineligible under statutory or regulatory authority other than
Executive Order 12549.”
Cause: The current staff was not able to find procurement documentation prepared before they were hired.
Effect: The District was unable to provide evidence that it was in compliance with the Uniform Guidance
requirement to maintain documentation of procurement procedures.
Context: The original procurement for the consulting firm for the Woodland Transit Project was performed in
late December 2017 and awarded in January 2018 and then extended during 2024. This procurement precedes
the current staff. It was verified the contractor selected was not debarred during the 2024 single audit.
Recommendation: We recommend the District establish a procurement folder on its server with subfolders for
each individual procurement where documentation of each procurement is maintained, including advertising of
the procurement, requests for proposals, proposals received, analysis of reasons for selecting the winning bid,
executed contract, certifications by contractor if not part of the proposal or executed contract, management
report to board recommending which bid should be approved, board resolution approving the winning bid and
for contracts under $250,000 a memo or form documenting bids received and reason for selecting the bid,
including reasons for not selecting the lowest bid if applicable. We also recommend training be provided to
staff that work on procurements of the requirements under Uniform Guidance Section 2 CFR 200.318 to
200.326.
View of Responsible Officials and Planned Corrective Action: Management’s response and planned
corrective action is included at the Corrective Action Plan end of this report.