Federal Program Title: Community Development Block Grants/Entitlements Grants
Federal Catalog Number: 14.218
Federal Agency: U.S. Department of Housing and Urban Development
Category of Finding: Program Income
Criteria: Office of Management and Budget (OMB) 2 CFR Part 200, Subpart D, Section 200.307(a), requires
that Program income must be expended prior to requesting additional Federal funds. Program income exceeding
amounts specified in the Federal award may be added to or deducted from the total allowable costs in
accordance with the terms and conditions of the Federal award.
Condition: During our audit, it was noted that the City recorded part of the program income as deferred revenue
rather than recognizing the full amount upon receiving the gross income earned and generated by CDBG loan
activity
Cause: Lack of appropriate controls over program income.
Effect or Potential Effect: Failure to properly report and manage program income could result in noncompliance
with federal regulations, potential repayment of misused funds, and could jeopardize future funding
opportunities. Furthermore, the mismanagement of program income could lead to inaccurate financial reporting
and a lack of accountability in the program's financial operations.
Questioned Cost: $152,065
Context: Program income is still in the process of being reconciled for prior and current year. It appears
that the current personnel have a misunderstanding regarding the recording and use of program income.
Repeat of a Prior-Year Finding: No.
Recommendation: We recommend the City to implement a comprehensive program income tracking and
reporting system that ensures compliance with federal regulations. The system should include detailed
procedures for documenting income generated, ensuring the funds are allocated to the proper grant or
project, and reporting the income accurately in accordance with grant terms. Regular training should also
be provided to staff responsible for grant management to ensure adherence to federal guidelines and the
organization’s internal controls.
City's Response: The City is aware of the OMB 2 CFR Part 200 regulations that pertain to program income
and will improve its internal controls to ensure compliance with federal regulations.
Corrective Action Plan: The City will improve its internal controls by implementing a new policy and
procedures that will require staff training and outline detailed procedures for complying with program
income regulations. The policy will: (1) require staff to annually participate in HUD trainings related to
program income, (2) require staff to immediately deposit and reconcile program income upon receipt, (3)
require staff to prepare a monthly program income report and (4) require management to review the
program income report to ensure program income is applied to eligible expenses prior to drawing down
grant funds.
Planned Implementation Date: March 25, 2025
Responsible Person(s): Albert Ramirez, Assistant Director; Denise Ledesma, Grants Coordinator; and
Adrianne Sarreal, Analyst.
Federal Program Title: Community Development Block Grants/Entitlements Grants
Federal Catalog Number: 14.218
Federal Agency: U.S. Department of Housing and Urban Development
Category of Finding: Program Income
Criteria: Office of Management and Budget (OMB) 2 CFR Part 200, Subpart D, Section 200.307(a), requires
that Program income must be expended prior to requesting additional Federal funds. Program income exceeding
amounts specified in the Federal award may be added to or deducted from the total allowable costs in
accordance with the terms and conditions of the Federal award.
Condition: During our audit, it was noted that the City recorded part of the program income as deferred revenue
rather than recognizing the full amount upon receiving the gross income earned and generated by CDBG loan
activity
Cause: Lack of appropriate controls over program income.
Effect or Potential Effect: Failure to properly report and manage program income could result in noncompliance
with federal regulations, potential repayment of misused funds, and could jeopardize future funding
opportunities. Furthermore, the mismanagement of program income could lead to inaccurate financial reporting
and a lack of accountability in the program's financial operations.
Questioned Cost: $152,065
Context: Program income is still in the process of being reconciled for prior and current year. It appears
that the current personnel have a misunderstanding regarding the recording and use of program income.
Repeat of a Prior-Year Finding: No.
Recommendation: We recommend the City to implement a comprehensive program income tracking and
reporting system that ensures compliance with federal regulations. The system should include detailed
procedures for documenting income generated, ensuring the funds are allocated to the proper grant or
project, and reporting the income accurately in accordance with grant terms. Regular training should also
be provided to staff responsible for grant management to ensure adherence to federal guidelines and the
organization’s internal controls.
City's Response: The City is aware of the OMB 2 CFR Part 200 regulations that pertain to program income
and will improve its internal controls to ensure compliance with federal regulations.
Corrective Action Plan: The City will improve its internal controls by implementing a new policy and
procedures that will require staff training and outline detailed procedures for complying with program
income regulations. The policy will: (1) require staff to annually participate in HUD trainings related to
program income, (2) require staff to immediately deposit and reconcile program income upon receipt, (3)
require staff to prepare a monthly program income report and (4) require management to review the
program income report to ensure program income is applied to eligible expenses prior to drawing down
grant funds.
Planned Implementation Date: March 25, 2025
Responsible Person(s): Albert Ramirez, Assistant Director; Denise Ledesma, Grants Coordinator; and
Adrianne Sarreal, Analyst.
Federal Program Title: Community Development Block Grants/Entitlements Grants
Federal Catalog Number: 14.218
Federal Agency: U.S. Department of Housing and Urban Development
Category of Finding: Reporting
Criteria: Pursuant to the OMB 2 CFR Part 200, Appendix XI, Compliance Supplement May 2024, Part 4 –
14.218 Community Development Block Grants/Entitlements Grants (page 4-14.218-25 & 26), the Cash on Hand
Quarterly Report, must be submitted to the grantee’s HUD local field office within 30 days after the end of the
reporting period.
Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as
amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified
in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward
Reporting System (FSRS). The recipient must also report a subaward if a modification increases the Federal
funding to an amount that equals or exceeds $30,000. All reported subawards should reflect the total amount of
the subaward. For subaward information, report no later than the end of the month following the month in which
the subaward was issued. (For example, if the subaward was made on November 7, 2025, the subaward must
be reported by no later than December 31, 2025).
Condition: The City failed to submit all of the Fiscal Year 2024 Cash on Hand Quarterly Reports within the
required 30-day period following each reporting quarter until February 2025. The City did not submit subaward
information for subrecipients receiving federal funds of $30,000 or more from the City to the FSRS until February
2025. These reports were due by the end of the month following the issuance of each subaward. Additionally,
staff responsible for financial reporting were not adequately trained on the specific requirements for reporting
under federal grants, which contributed to the late submission of the reports.
Cause: Lack of appropriate control over reporting.
Effect or Potential Effect: Noncompliance may result in suspension, termination, or disallowance of grant funds,
and delay or withhold of future grant payments.
Questioned Cost: None.
Repeat of a Prior-Year Finding: No.
Recommendation: We recommend that the City develop and implement policies and procedures for
completeness and timely submission of reports. This may include:
1. Thoroughly review the reporting requirements each year for any possible updates, substitutions, or
missing reports, and document the process, including the preparer and reviewer.
2. Prepare a listing of subaward agreements, including details such as the subrecipient, original and
amended amounts, execution date (i.e., when it becomes legally binding), reporting date, name of the
person who submitted the report, name of the person who reviewed the report, etc., for each program to
identify and track the reporting of subaward information.
3. Staff responsible for financial reporting should receive specific training on federal reporting requirements
to ensure accuracy and compliance.
City's Response: The City is aware of the OMB 2 CFR Part 200 regulations that pertain to Cash on Hand
Report and Federal Funding Accountability and Transparency Act (FFATA) reporting.
With respect to the Cash on Hand Report, staff reviewed the published HUD guidance but needed further
clarification to properly complete the report. Staff reached out to our HUD Representative and received
clarification. Staff has all the information needed to properly complete the report and plan to submit the
report quarterly as required.
With respect to the FFATA Reporting, staff inadvertently thought the report was due annually, rather than
monthly.
Corrective Action Plan: The City will improve its internal controls by implementing a new policy and
procedures that will: (1) require staff to annually participate in HUD trainings related to federal grant
reporting, (2) require management and staff to meet monthly to discuss and track federal reporting
requirements and review a listing of subaward agreements and (3) require staff to submit the Cash on
Hand Report quarterly and the FFATA Report monthly.
Planned Implementation Date: March 25, 2025
Responsible Person(s): Albert Ramirez, Assistant Director; Denise Ledesma, Grants Coordinator; and
Adrianne Sarreal, Analyst.
Federal Program Title: Community Development Block Grants/Entitlements Grants
Federal Catalog Number: 14.218
Federal Agency: U.S. Department of Housing and Urban Development
Category of Finding: Reporting
Criteria: Pursuant to the OMB 2 CFR Part 200, Appendix XI, Compliance Supplement May 2024, Part 4 –
14.218 Community Development Block Grants/Entitlements Grants (page 4-14.218-25 & 26), the Cash on Hand
Quarterly Report, must be submitted to the grantee’s HUD local field office within 30 days after the end of the
reporting period.
Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as
amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified
in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward
Reporting System (FSRS). The recipient must also report a subaward if a modification increases the Federal
funding to an amount that equals or exceeds $30,000. All reported subawards should reflect the total amount of
the subaward. For subaward information, report no later than the end of the month following the month in which
the subaward was issued. (For example, if the subaward was made on November 7, 2025, the subaward must
be reported by no later than December 31, 2025).
Condition: The City failed to submit all of the Fiscal Year 2024 Cash on Hand Quarterly Reports within the
required 30-day period following each reporting quarter until February 2025. The City did not submit subaward
information for subrecipients receiving federal funds of $30,000 or more from the City to the FSRS until February
2025. These reports were due by the end of the month following the issuance of each subaward. Additionally,
staff responsible for financial reporting were not adequately trained on the specific requirements for reporting
under federal grants, which contributed to the late submission of the reports.
Cause: Lack of appropriate control over reporting.
Effect or Potential Effect: Noncompliance may result in suspension, termination, or disallowance of grant funds,
and delay or withhold of future grant payments.
Questioned Cost: None.
Repeat of a Prior-Year Finding: No.
Recommendation: We recommend that the City develop and implement policies and procedures for
completeness and timely submission of reports. This may include:
1. Thoroughly review the reporting requirements each year for any possible updates, substitutions, or
missing reports, and document the process, including the preparer and reviewer.
2. Prepare a listing of subaward agreements, including details such as the subrecipient, original and
amended amounts, execution date (i.e., when it becomes legally binding), reporting date, name of the
person who submitted the report, name of the person who reviewed the report, etc., for each program to
identify and track the reporting of subaward information.
3. Staff responsible for financial reporting should receive specific training on federal reporting requirements
to ensure accuracy and compliance.
City's Response: The City is aware of the OMB 2 CFR Part 200 regulations that pertain to Cash on Hand
Report and Federal Funding Accountability and Transparency Act (FFATA) reporting.
With respect to the Cash on Hand Report, staff reviewed the published HUD guidance but needed further
clarification to properly complete the report. Staff reached out to our HUD Representative and received
clarification. Staff has all the information needed to properly complete the report and plan to submit the
report quarterly as required.
With respect to the FFATA Reporting, staff inadvertently thought the report was due annually, rather than
monthly.
Corrective Action Plan: The City will improve its internal controls by implementing a new policy and
procedures that will: (1) require staff to annually participate in HUD trainings related to federal grant
reporting, (2) require management and staff to meet monthly to discuss and track federal reporting
requirements and review a listing of subaward agreements and (3) require staff to submit the Cash on
Hand Report quarterly and the FFATA Report monthly.
Planned Implementation Date: March 25, 2025
Responsible Person(s): Albert Ramirez, Assistant Director; Denise Ledesma, Grants Coordinator; and
Adrianne Sarreal, Analyst.
Federal Program Title: Staffing for Adequate Fire & Emergency Response
Federal Catalog Number: 97.083
Federal Agency: U.S. Department of Homeland Security
Category of Finding: Reporting
Criteria: According to Notice of Funding Opportunity (NOFO) Fiscal Year 2023 Staffing for Adequate Fire and
Emergency Response (SAFER) Grant program, recipients are required to submit semi-annual Federal Financial
Reports and Program Performance Reports within 30 days after the end of each reporting period.
Condition: The City submitted the Performance Progress Report for the period of January 2024 to June 2024
one day late, and the Federal Financial Report for the period of July 2023 to December 2023 three months late.
Cause: The primary cause of the delayed financial reporting was the unexpected turnover of key staff members
responsible for financial reporting. The City did not have sufficient backup procedures in place to ensure a
smooth transition or proper training for new personnel in time to meet reporting deadlines. This lack of continuity
resulted in delays in financial data preparation.
Effect or Potential Effect: The delays in financial reporting may lead to non-compliance with federal reporting
requirements. This could impact the City’s standing with the funding agency, potentially affecting future funding
opportunities
Questioned Cost: None.
Repeat of a Prior-Year Finding: No.
Recommendation: We recommend the City to establish a contingency plan to address staff turnover, including
cross-training key personnel and maintaining detailed documentation of financial reporting processes. The City
should also implement a standardized handoff procedure to ensure that incoming staff are adequately trained
and have access to the necessary resources to continue the reporting function without disruption.
Management Response and Corrective Action Plan
City's Response: As noted in the auditor findings, the late filings for Safer Grant Reporting in Fiscal Year
2024 were due to turnover in the department’s grant administrator position and the redistribution of work
responsibilities. The slight delays in the reporting did not produce any notice of non-compliance or drawdown
withholdings by the Grantor. The Department has completed the redistribution of work
responsibilities and now has a dedicated grant administrator and management oversight.
Corrective Action Plan: The department will develop a contingency plan and training procedures to
ensure continuity of grant procedures and a review process to ensure reporting accuracy.
Planned Implementation Date: June 30,2025
Responsible Person(s): Rose Rodarte and Francine Gutierrez
Federal Program Title: Staffing for Adequate Fire & Emergency Response
Federal Catalog Number: 97.083
Federal Agency: U.S. Department of Homeland Security
Category of Finding: Activities Allowed/Unallowed
Criteria: According to 2 CFR 200.430, employees working on federally funded projects are required to submit
timesheets that accurately reflect the time spent on the project. These timesheets must be approved by a
responsible supervisor to ensure that the reported hours are accurate, reasonable, and properly allocated.
Additionally, organizations must establish and maintain effective internal controls to ensure compliance with
timekeeping and payroll procedures.
Condition: During the audit, it was found that the City's time roster report approval process was not consistently
followed. We selected four pay periods for testing. In two of these periods, the time roster reports were not
properly reviewed and approved by a battalion chief supervisor before submission for payroll processing. These
time roster reports were automatically approved by the system to meet payroll processing deadlines, bypassing
the required supervisory review.
Cause: The failure to adhere to the time roster report approval process was due to a lack of oversight and
insufficient enforcement of internal control procedures.
Effect or Potential Effect: The lack of proper time roster approval creates a risk of inaccuracies in the allocation
of payroll costs to federal grants, which could result in non-compliance with federal regulations. Additionally,
failure to follow the required process could lead to improper charging of labor costs, potentially jeopardizing the
City’s eligibility for future funding and risking the disallowance of grant-related costs.
Questioned Cost: None.
Repeat of a Prior-Year Finding: No.
Recommendation: We recommend the City to strengthen its internal controls related to time roster report
approval. Specifically, a formal time roster report approval process should be implemented that includes clear
guidelines for timely approval by supervisors. The City should also establish a tracking system to ensure that
time roster report is approved before submission for payroll processing. Regular training for staff and supervisors
on the importance of accurate timekeeping and approval procedures should be conducted to reinforce
compliance with federal grant requirements.
Management Response and Corrective Action Plan
City's Response: The City uses Telestaff to maintain Fire employees’ work schedules and as the system
of record for payroll timekeeping. The audit identified several rosters that were not finalized (approved) by
the Duty Chief before the conclusion of their shift and were auto-finalized by the system. Going forward,
the City will ensure that the finalization process by the Duty Chief, which essentially serves to confirm that
the time and attendance as reflected in Telestaff is what was actually worked, is adhered to. Oxnard Fire
Department Policy 1005 requires that the Duty Chief review and approve the roster at the conclusion of
their shift to verify the accuracy of the roster for payroll processing.
In instances where overtime related to late relief is in unapproved status (depicted with an asterisk in the
system), the Duty Chief will ensure the late relief is approved before finalizing the daily roster.
After the roster is finalized (approved) by the Duty Chief, the timekeeper reviews the roster for the
appropriate general ledger account(s), paycode(s), and project coding to ensure proper accounting of
payroll costs. If the Duty Chief has not finalized the roster by 0800, the timekeeper will inform the
Department Assistant Chiefs to initiate completion of the task.
Corrective Action Plan: The Department will conduct a formal review of its processes and policies to
identify potential weaknesses in the payroll timekeeping and approval process, and will update its policies
and procedures to align with the roles and responsibilities of those involved in rostering and timekeeping.
The department has already taken corrective action to ensure that duty chiefs are finalizing the rosters
before the end of their shift and making it the responsibility of the timekeeper to initiate action when
finalization by the Duty Chiefs has not occurred so the timekeepers review process can be completed.
Planned Implementation Date: June 30, 2025
Responsible Person(s): Karsten Guthrie and Rose Rodarte
Federal Program Title: Community Development Block Grants/Entitlements Grants
Federal Catalog Number: 14.218
Federal Agency: U.S. Department of Housing and Urban Development
Category of Finding: Program Income
Criteria: Office of Management and Budget (OMB) 2 CFR Part 200, Subpart D, Section 200.307(a), requires
that Program income must be expended prior to requesting additional Federal funds. Program income exceeding
amounts specified in the Federal award may be added to or deducted from the total allowable costs in
accordance with the terms and conditions of the Federal award.
Condition: During our audit, it was noted that the City recorded part of the program income as deferred revenue
rather than recognizing the full amount upon receiving the gross income earned and generated by CDBG loan
activity
Cause: Lack of appropriate controls over program income.
Effect or Potential Effect: Failure to properly report and manage program income could result in noncompliance
with federal regulations, potential repayment of misused funds, and could jeopardize future funding
opportunities. Furthermore, the mismanagement of program income could lead to inaccurate financial reporting
and a lack of accountability in the program's financial operations.
Questioned Cost: $152,065
Context: Program income is still in the process of being reconciled for prior and current year. It appears
that the current personnel have a misunderstanding regarding the recording and use of program income.
Repeat of a Prior-Year Finding: No.
Recommendation: We recommend the City to implement a comprehensive program income tracking and
reporting system that ensures compliance with federal regulations. The system should include detailed
procedures for documenting income generated, ensuring the funds are allocated to the proper grant or
project, and reporting the income accurately in accordance with grant terms. Regular training should also
be provided to staff responsible for grant management to ensure adherence to federal guidelines and the
organization’s internal controls.
City's Response: The City is aware of the OMB 2 CFR Part 200 regulations that pertain to program income
and will improve its internal controls to ensure compliance with federal regulations.
Corrective Action Plan: The City will improve its internal controls by implementing a new policy and
procedures that will require staff training and outline detailed procedures for complying with program
income regulations. The policy will: (1) require staff to annually participate in HUD trainings related to
program income, (2) require staff to immediately deposit and reconcile program income upon receipt, (3)
require staff to prepare a monthly program income report and (4) require management to review the
program income report to ensure program income is applied to eligible expenses prior to drawing down
grant funds.
Planned Implementation Date: March 25, 2025
Responsible Person(s): Albert Ramirez, Assistant Director; Denise Ledesma, Grants Coordinator; and
Adrianne Sarreal, Analyst.
Federal Program Title: Community Development Block Grants/Entitlements Grants
Federal Catalog Number: 14.218
Federal Agency: U.S. Department of Housing and Urban Development
Category of Finding: Program Income
Criteria: Office of Management and Budget (OMB) 2 CFR Part 200, Subpart D, Section 200.307(a), requires
that Program income must be expended prior to requesting additional Federal funds. Program income exceeding
amounts specified in the Federal award may be added to or deducted from the total allowable costs in
accordance with the terms and conditions of the Federal award.
Condition: During our audit, it was noted that the City recorded part of the program income as deferred revenue
rather than recognizing the full amount upon receiving the gross income earned and generated by CDBG loan
activity
Cause: Lack of appropriate controls over program income.
Effect or Potential Effect: Failure to properly report and manage program income could result in noncompliance
with federal regulations, potential repayment of misused funds, and could jeopardize future funding
opportunities. Furthermore, the mismanagement of program income could lead to inaccurate financial reporting
and a lack of accountability in the program's financial operations.
Questioned Cost: $152,065
Context: Program income is still in the process of being reconciled for prior and current year. It appears
that the current personnel have a misunderstanding regarding the recording and use of program income.
Repeat of a Prior-Year Finding: No.
Recommendation: We recommend the City to implement a comprehensive program income tracking and
reporting system that ensures compliance with federal regulations. The system should include detailed
procedures for documenting income generated, ensuring the funds are allocated to the proper grant or
project, and reporting the income accurately in accordance with grant terms. Regular training should also
be provided to staff responsible for grant management to ensure adherence to federal guidelines and the
organization’s internal controls.
City's Response: The City is aware of the OMB 2 CFR Part 200 regulations that pertain to program income
and will improve its internal controls to ensure compliance with federal regulations.
Corrective Action Plan: The City will improve its internal controls by implementing a new policy and
procedures that will require staff training and outline detailed procedures for complying with program
income regulations. The policy will: (1) require staff to annually participate in HUD trainings related to
program income, (2) require staff to immediately deposit and reconcile program income upon receipt, (3)
require staff to prepare a monthly program income report and (4) require management to review the
program income report to ensure program income is applied to eligible expenses prior to drawing down
grant funds.
Planned Implementation Date: March 25, 2025
Responsible Person(s): Albert Ramirez, Assistant Director; Denise Ledesma, Grants Coordinator; and
Adrianne Sarreal, Analyst.
Federal Program Title: Community Development Block Grants/Entitlements Grants
Federal Catalog Number: 14.218
Federal Agency: U.S. Department of Housing and Urban Development
Category of Finding: Reporting
Criteria: Pursuant to the OMB 2 CFR Part 200, Appendix XI, Compliance Supplement May 2024, Part 4 –
14.218 Community Development Block Grants/Entitlements Grants (page 4-14.218-25 & 26), the Cash on Hand
Quarterly Report, must be submitted to the grantee’s HUD local field office within 30 days after the end of the
reporting period.
Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as
amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified
in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward
Reporting System (FSRS). The recipient must also report a subaward if a modification increases the Federal
funding to an amount that equals or exceeds $30,000. All reported subawards should reflect the total amount of
the subaward. For subaward information, report no later than the end of the month following the month in which
the subaward was issued. (For example, if the subaward was made on November 7, 2025, the subaward must
be reported by no later than December 31, 2025).
Condition: The City failed to submit all of the Fiscal Year 2024 Cash on Hand Quarterly Reports within the
required 30-day period following each reporting quarter until February 2025. The City did not submit subaward
information for subrecipients receiving federal funds of $30,000 or more from the City to the FSRS until February
2025. These reports were due by the end of the month following the issuance of each subaward. Additionally,
staff responsible for financial reporting were not adequately trained on the specific requirements for reporting
under federal grants, which contributed to the late submission of the reports.
Cause: Lack of appropriate control over reporting.
Effect or Potential Effect: Noncompliance may result in suspension, termination, or disallowance of grant funds,
and delay or withhold of future grant payments.
Questioned Cost: None.
Repeat of a Prior-Year Finding: No.
Recommendation: We recommend that the City develop and implement policies and procedures for
completeness and timely submission of reports. This may include:
1. Thoroughly review the reporting requirements each year for any possible updates, substitutions, or
missing reports, and document the process, including the preparer and reviewer.
2. Prepare a listing of subaward agreements, including details such as the subrecipient, original and
amended amounts, execution date (i.e., when it becomes legally binding), reporting date, name of the
person who submitted the report, name of the person who reviewed the report, etc., for each program to
identify and track the reporting of subaward information.
3. Staff responsible for financial reporting should receive specific training on federal reporting requirements
to ensure accuracy and compliance.
City's Response: The City is aware of the OMB 2 CFR Part 200 regulations that pertain to Cash on Hand
Report and Federal Funding Accountability and Transparency Act (FFATA) reporting.
With respect to the Cash on Hand Report, staff reviewed the published HUD guidance but needed further
clarification to properly complete the report. Staff reached out to our HUD Representative and received
clarification. Staff has all the information needed to properly complete the report and plan to submit the
report quarterly as required.
With respect to the FFATA Reporting, staff inadvertently thought the report was due annually, rather than
monthly.
Corrective Action Plan: The City will improve its internal controls by implementing a new policy and
procedures that will: (1) require staff to annually participate in HUD trainings related to federal grant
reporting, (2) require management and staff to meet monthly to discuss and track federal reporting
requirements and review a listing of subaward agreements and (3) require staff to submit the Cash on
Hand Report quarterly and the FFATA Report monthly.
Planned Implementation Date: March 25, 2025
Responsible Person(s): Albert Ramirez, Assistant Director; Denise Ledesma, Grants Coordinator; and
Adrianne Sarreal, Analyst.
Federal Program Title: Community Development Block Grants/Entitlements Grants
Federal Catalog Number: 14.218
Federal Agency: U.S. Department of Housing and Urban Development
Category of Finding: Reporting
Criteria: Pursuant to the OMB 2 CFR Part 200, Appendix XI, Compliance Supplement May 2024, Part 4 –
14.218 Community Development Block Grants/Entitlements Grants (page 4-14.218-25 & 26), the Cash on Hand
Quarterly Report, must be submitted to the grantee’s HUD local field office within 30 days after the end of the
reporting period.
Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as
amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified
in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward
Reporting System (FSRS). The recipient must also report a subaward if a modification increases the Federal
funding to an amount that equals or exceeds $30,000. All reported subawards should reflect the total amount of
the subaward. For subaward information, report no later than the end of the month following the month in which
the subaward was issued. (For example, if the subaward was made on November 7, 2025, the subaward must
be reported by no later than December 31, 2025).
Condition: The City failed to submit all of the Fiscal Year 2024 Cash on Hand Quarterly Reports within the
required 30-day period following each reporting quarter until February 2025. The City did not submit subaward
information for subrecipients receiving federal funds of $30,000 or more from the City to the FSRS until February
2025. These reports were due by the end of the month following the issuance of each subaward. Additionally,
staff responsible for financial reporting were not adequately trained on the specific requirements for reporting
under federal grants, which contributed to the late submission of the reports.
Cause: Lack of appropriate control over reporting.
Effect or Potential Effect: Noncompliance may result in suspension, termination, or disallowance of grant funds,
and delay or withhold of future grant payments.
Questioned Cost: None.
Repeat of a Prior-Year Finding: No.
Recommendation: We recommend that the City develop and implement policies and procedures for
completeness and timely submission of reports. This may include:
1. Thoroughly review the reporting requirements each year for any possible updates, substitutions, or
missing reports, and document the process, including the preparer and reviewer.
2. Prepare a listing of subaward agreements, including details such as the subrecipient, original and
amended amounts, execution date (i.e., when it becomes legally binding), reporting date, name of the
person who submitted the report, name of the person who reviewed the report, etc., for each program to
identify and track the reporting of subaward information.
3. Staff responsible for financial reporting should receive specific training on federal reporting requirements
to ensure accuracy and compliance.
City's Response: The City is aware of the OMB 2 CFR Part 200 regulations that pertain to Cash on Hand
Report and Federal Funding Accountability and Transparency Act (FFATA) reporting.
With respect to the Cash on Hand Report, staff reviewed the published HUD guidance but needed further
clarification to properly complete the report. Staff reached out to our HUD Representative and received
clarification. Staff has all the information needed to properly complete the report and plan to submit the
report quarterly as required.
With respect to the FFATA Reporting, staff inadvertently thought the report was due annually, rather than
monthly.
Corrective Action Plan: The City will improve its internal controls by implementing a new policy and
procedures that will: (1) require staff to annually participate in HUD trainings related to federal grant
reporting, (2) require management and staff to meet monthly to discuss and track federal reporting
requirements and review a listing of subaward agreements and (3) require staff to submit the Cash on
Hand Report quarterly and the FFATA Report monthly.
Planned Implementation Date: March 25, 2025
Responsible Person(s): Albert Ramirez, Assistant Director; Denise Ledesma, Grants Coordinator; and
Adrianne Sarreal, Analyst.
Federal Program Title: Staffing for Adequate Fire & Emergency Response
Federal Catalog Number: 97.083
Federal Agency: U.S. Department of Homeland Security
Category of Finding: Reporting
Criteria: According to Notice of Funding Opportunity (NOFO) Fiscal Year 2023 Staffing for Adequate Fire and
Emergency Response (SAFER) Grant program, recipients are required to submit semi-annual Federal Financial
Reports and Program Performance Reports within 30 days after the end of each reporting period.
Condition: The City submitted the Performance Progress Report for the period of January 2024 to June 2024
one day late, and the Federal Financial Report for the period of July 2023 to December 2023 three months late.
Cause: The primary cause of the delayed financial reporting was the unexpected turnover of key staff members
responsible for financial reporting. The City did not have sufficient backup procedures in place to ensure a
smooth transition or proper training for new personnel in time to meet reporting deadlines. This lack of continuity
resulted in delays in financial data preparation.
Effect or Potential Effect: The delays in financial reporting may lead to non-compliance with federal reporting
requirements. This could impact the City’s standing with the funding agency, potentially affecting future funding
opportunities
Questioned Cost: None.
Repeat of a Prior-Year Finding: No.
Recommendation: We recommend the City to establish a contingency plan to address staff turnover, including
cross-training key personnel and maintaining detailed documentation of financial reporting processes. The City
should also implement a standardized handoff procedure to ensure that incoming staff are adequately trained
and have access to the necessary resources to continue the reporting function without disruption.
Management Response and Corrective Action Plan
City's Response: As noted in the auditor findings, the late filings for Safer Grant Reporting in Fiscal Year
2024 were due to turnover in the department’s grant administrator position and the redistribution of work
responsibilities. The slight delays in the reporting did not produce any notice of non-compliance or drawdown
withholdings by the Grantor. The Department has completed the redistribution of work
responsibilities and now has a dedicated grant administrator and management oversight.
Corrective Action Plan: The department will develop a contingency plan and training procedures to
ensure continuity of grant procedures and a review process to ensure reporting accuracy.
Planned Implementation Date: June 30,2025
Responsible Person(s): Rose Rodarte and Francine Gutierrez
Federal Program Title: Staffing for Adequate Fire & Emergency Response
Federal Catalog Number: 97.083
Federal Agency: U.S. Department of Homeland Security
Category of Finding: Activities Allowed/Unallowed
Criteria: According to 2 CFR 200.430, employees working on federally funded projects are required to submit
timesheets that accurately reflect the time spent on the project. These timesheets must be approved by a
responsible supervisor to ensure that the reported hours are accurate, reasonable, and properly allocated.
Additionally, organizations must establish and maintain effective internal controls to ensure compliance with
timekeeping and payroll procedures.
Condition: During the audit, it was found that the City's time roster report approval process was not consistently
followed. We selected four pay periods for testing. In two of these periods, the time roster reports were not
properly reviewed and approved by a battalion chief supervisor before submission for payroll processing. These
time roster reports were automatically approved by the system to meet payroll processing deadlines, bypassing
the required supervisory review.
Cause: The failure to adhere to the time roster report approval process was due to a lack of oversight and
insufficient enforcement of internal control procedures.
Effect or Potential Effect: The lack of proper time roster approval creates a risk of inaccuracies in the allocation
of payroll costs to federal grants, which could result in non-compliance with federal regulations. Additionally,
failure to follow the required process could lead to improper charging of labor costs, potentially jeopardizing the
City’s eligibility for future funding and risking the disallowance of grant-related costs.
Questioned Cost: None.
Repeat of a Prior-Year Finding: No.
Recommendation: We recommend the City to strengthen its internal controls related to time roster report
approval. Specifically, a formal time roster report approval process should be implemented that includes clear
guidelines for timely approval by supervisors. The City should also establish a tracking system to ensure that
time roster report is approved before submission for payroll processing. Regular training for staff and supervisors
on the importance of accurate timekeeping and approval procedures should be conducted to reinforce
compliance with federal grant requirements.
Management Response and Corrective Action Plan
City's Response: The City uses Telestaff to maintain Fire employees’ work schedules and as the system
of record for payroll timekeeping. The audit identified several rosters that were not finalized (approved) by
the Duty Chief before the conclusion of their shift and were auto-finalized by the system. Going forward,
the City will ensure that the finalization process by the Duty Chief, which essentially serves to confirm that
the time and attendance as reflected in Telestaff is what was actually worked, is adhered to. Oxnard Fire
Department Policy 1005 requires that the Duty Chief review and approve the roster at the conclusion of
their shift to verify the accuracy of the roster for payroll processing.
In instances where overtime related to late relief is in unapproved status (depicted with an asterisk in the
system), the Duty Chief will ensure the late relief is approved before finalizing the daily roster.
After the roster is finalized (approved) by the Duty Chief, the timekeeper reviews the roster for the
appropriate general ledger account(s), paycode(s), and project coding to ensure proper accounting of
payroll costs. If the Duty Chief has not finalized the roster by 0800, the timekeeper will inform the
Department Assistant Chiefs to initiate completion of the task.
Corrective Action Plan: The Department will conduct a formal review of its processes and policies to
identify potential weaknesses in the payroll timekeeping and approval process, and will update its policies
and procedures to align with the roles and responsibilities of those involved in rostering and timekeeping.
The department has already taken corrective action to ensure that duty chiefs are finalizing the rosters
before the end of their shift and making it the responsibility of the timekeeper to initiate action when
finalization by the Duty Chiefs has not occurred so the timekeepers review process can be completed.
Planned Implementation Date: June 30, 2025
Responsible Person(s): Karsten Guthrie and Rose Rodarte