FINDING 2023-001
Information on the federal program:
Federal Agency: Department of the Treasury
Pass-Through Entity: N/A – Direct Grant
Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Assistance Listing Number: 21.027
Compliance Requirement: Subrecipient Monitoring
Audit Findings: Material Weakness, Noncompliance
Criteria: Title 2 Subtitle A Chapter II Part 200 Subparts A and D, Section 200.332, establishes requirements
that pass-through entities must adhere to in regard to their subrecipient grant agreements and the
monitoring processes of those subrecipients.
Condition: The City of Bloomington was unable to identify subrecipients of CSLFRF funding for the
purposes of financial reporting and compliance with requirements under 2 CFR 200.332. The City could not
distinguish between a subrecipient and a general vendor. Management misreported subrecipient activity
on the SEFA, failed to include required contractual language for subrecipient awards in executed
agreements, and did not perform monitoring procedures over the subrecipients management identified
during audit testing procedures.
Cause: The City does not have an effective system of internal controls in place to effectively structure and
review CSLFRF subaward agreements or to effectively monitor subrecipients.
Effect: Due to lack of required information being present with agreements and the contracts not clearly
differentiating between a subrecipient and a beneficiary, there could be noncompliance issues in how funds
are spent and recorded by the subrecipient, which could lead to noncompliance issues for the City of
Bloomington and its subrecipients.
Questioned costs: There are no questioned costs.
Context: The 10 subrecipients represent approximately 18%, $1,025,070, of the total award expenditures
of $5,590,828, in 2023. The condition reported was prevalent for each subrecipient participating in the
award.
Identification as a repeat finding, if applicable: Yes, finding 2022-002 in the prior year report.
Recommendation: We recommend that the City institute a policy for the handling of subrecipients for all
sources of federal funding. The City should review Title 2 Subtitle A Chapter II Part 200 Subpart A and
ensure their agreements with subrecipients include all required information. Management should review
Title 2 Subtitle A Chapter II Part 200 Subpart D and ensure all necessary monitoring procedures are being
performed over subrecipients moving forward.
Views of responsible officials and planned corrective actions: Management acknowledges the
finding. See management’s corrective action plan attached to this audit report.
FINDING 2023-002
Information on the federal program:
Federal Agency: Department of the Treasury
Pass-Through Entity: N/A – Direct Grant
Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Assistance Listing Number: 21.027
Compliance Requirement: Reporting
Audit Findings: Significant Deficiency
Criteria: The US Department of Treasury’s Compliance and Reporting Guidance for State and Local Fiscal
Recovery Funds requires quarterly project expenditure reports to be completed with the key line items: 1)
Obligations and Expenditures 2) Subawards 3) Detailed information of any loans issued; contracts and
grants awarded; transfers made to other government entities; and direct payments made by the recipient
that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate
for these same categories of loans issued; contracts and grants awarded; transfers made to other
government entities; and direct payments made by the recipient.
Condition: City of Bloomington completed quarterly reporting in a timely manner substantiated by the City’s
expenditure detail. However, management could not differentiate between subrecipients and standard
vendor purchases.
Cause: The City does not have an effective system of internal controls in place to effectively review
CSLFRF reporting data prior to submission to the US Department of Treasury.
Effect: Subrecipient expenditures and subawards on the quarterly data submissions were overstated.
Questioned costs: There are no questioned costs.
Context: During our testing procedures over CSLFRF reporting, we noted that segregation of duties is not
present in the Federal reporting process. The Deputy Controller prepared and submitted the reports without
a secondary review taking place. As a result, the City did not report expenditures for the grant that were
consistent with the expenditures reported on the SEFA and could not properly identify subrecipient
expenditures.
Identification as a repeat finding, if applicable: Yes, finding 2022-003 in the prior year report.
Recommendation: We recommend that the City implement a consistent multi-stage review process for
federal data reports, which involves identifying and tracking subrecipient activity as well as expenditures by
type.
Views of responsible officials and planned corrective actions: Management acknowledges the finding.
See management’s corrective action plan attached to this audit report.
FINDING 2023-003
Information on the federal program:
Federal Agency: Department of the Treasury
Pass-Through Entity: N/A – Direct Grant
Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Assistance Listing Number: 21.027
Compliance Requirement: Procurement – Suspension and Debarment
Audit Findings: Significant Deficiency, Noncompliance
Criteria: 2 CFR 180.300 states: “When you enter into a covered transaction with another person at the
next lower tier, you must verify that the person with whom you intend to do business is not excluded or
disqualified. You do this by:
a) Checking the SAM Exclusions; or
b) Collecting a certification from that person; or
c) Adding a clause or condition to the covered transaction with that person.”
Condition: The City of Bloomington could not provide documentation to support that vendors procured
under CSLFRF funding were not suspended or debarred.
Cause: The City had not developed a system of internal controls that would have ensured compliance with
Procurement and Suspension and Debarment compliance requirements for covered transactions.
Effect: The failure to establish internal controls could have enabled noncompliance to go undetected. If
vendors would have been suspended or debarred, the failure to comply with the grant agreement and the
compliance requirement could have resulted in the loss of federal funds to the City.
Questioned costs: There are no questioned costs.
Context: In a sample of five vendors with aggregate disbursements for FY2023 above the $25,000 covered
transaction threshold, Crowe noted for each selection that the City had not completed a check for
suspension and debarment nor had had they obtained a contract clause from the vendor/service provider
certifying that they were not suspended and/or debarred.
Identification as a repeat finding, if applicable: Yes, finding 2022-004 in the prior year report.
Recommendation: We recommend that the City establish and implement control procedures to ensure
compliance with the grant agreement and the Procurement and Suspension and Debarment compliance
requirement. This should include ensuring suspension and debarment checks are performed and
documented prior to entering into the transaction.
Views of responsible officials and planned corrective actions: Management acknowledges the
finding. See management’s corrective action plan attached to this audit report.
FINDING 2023-001
Information on the federal program:
Federal Agency: Department of the Treasury
Pass-Through Entity: N/A – Direct Grant
Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Assistance Listing Number: 21.027
Compliance Requirement: Subrecipient Monitoring
Audit Findings: Material Weakness, Noncompliance
Criteria: Title 2 Subtitle A Chapter II Part 200 Subparts A and D, Section 200.332, establishes requirements
that pass-through entities must adhere to in regard to their subrecipient grant agreements and the
monitoring processes of those subrecipients.
Condition: The City of Bloomington was unable to identify subrecipients of CSLFRF funding for the
purposes of financial reporting and compliance with requirements under 2 CFR 200.332. The City could not
distinguish between a subrecipient and a general vendor. Management misreported subrecipient activity
on the SEFA, failed to include required contractual language for subrecipient awards in executed
agreements, and did not perform monitoring procedures over the subrecipients management identified
during audit testing procedures.
Cause: The City does not have an effective system of internal controls in place to effectively structure and
review CSLFRF subaward agreements or to effectively monitor subrecipients.
Effect: Due to lack of required information being present with agreements and the contracts not clearly
differentiating between a subrecipient and a beneficiary, there could be noncompliance issues in how funds
are spent and recorded by the subrecipient, which could lead to noncompliance issues for the City of
Bloomington and its subrecipients.
Questioned costs: There are no questioned costs.
Context: The 10 subrecipients represent approximately 18%, $1,025,070, of the total award expenditures
of $5,590,828, in 2023. The condition reported was prevalent for each subrecipient participating in the
award.
Identification as a repeat finding, if applicable: Yes, finding 2022-002 in the prior year report.
Recommendation: We recommend that the City institute a policy for the handling of subrecipients for all
sources of federal funding. The City should review Title 2 Subtitle A Chapter II Part 200 Subpart A and
ensure their agreements with subrecipients include all required information. Management should review
Title 2 Subtitle A Chapter II Part 200 Subpart D and ensure all necessary monitoring procedures are being
performed over subrecipients moving forward.
Views of responsible officials and planned corrective actions: Management acknowledges the
finding. See management’s corrective action plan attached to this audit report.
FINDING 2023-002
Information on the federal program:
Federal Agency: Department of the Treasury
Pass-Through Entity: N/A – Direct Grant
Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Assistance Listing Number: 21.027
Compliance Requirement: Reporting
Audit Findings: Significant Deficiency
Criteria: The US Department of Treasury’s Compliance and Reporting Guidance for State and Local Fiscal
Recovery Funds requires quarterly project expenditure reports to be completed with the key line items: 1)
Obligations and Expenditures 2) Subawards 3) Detailed information of any loans issued; contracts and
grants awarded; transfers made to other government entities; and direct payments made by the recipient
that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate
for these same categories of loans issued; contracts and grants awarded; transfers made to other
government entities; and direct payments made by the recipient.
Condition: City of Bloomington completed quarterly reporting in a timely manner substantiated by the City’s
expenditure detail. However, management could not differentiate between subrecipients and standard
vendor purchases.
Cause: The City does not have an effective system of internal controls in place to effectively review
CSLFRF reporting data prior to submission to the US Department of Treasury.
Effect: Subrecipient expenditures and subawards on the quarterly data submissions were overstated.
Questioned costs: There are no questioned costs.
Context: During our testing procedures over CSLFRF reporting, we noted that segregation of duties is not
present in the Federal reporting process. The Deputy Controller prepared and submitted the reports without
a secondary review taking place. As a result, the City did not report expenditures for the grant that were
consistent with the expenditures reported on the SEFA and could not properly identify subrecipient
expenditures.
Identification as a repeat finding, if applicable: Yes, finding 2022-003 in the prior year report.
Recommendation: We recommend that the City implement a consistent multi-stage review process for
federal data reports, which involves identifying and tracking subrecipient activity as well as expenditures by
type.
Views of responsible officials and planned corrective actions: Management acknowledges the finding.
See management’s corrective action plan attached to this audit report.
FINDING 2023-003
Information on the federal program:
Federal Agency: Department of the Treasury
Pass-Through Entity: N/A – Direct Grant
Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Assistance Listing Number: 21.027
Compliance Requirement: Procurement – Suspension and Debarment
Audit Findings: Significant Deficiency, Noncompliance
Criteria: 2 CFR 180.300 states: “When you enter into a covered transaction with another person at the
next lower tier, you must verify that the person with whom you intend to do business is not excluded or
disqualified. You do this by:
a) Checking the SAM Exclusions; or
b) Collecting a certification from that person; or
c) Adding a clause or condition to the covered transaction with that person.”
Condition: The City of Bloomington could not provide documentation to support that vendors procured
under CSLFRF funding were not suspended or debarred.
Cause: The City had not developed a system of internal controls that would have ensured compliance with
Procurement and Suspension and Debarment compliance requirements for covered transactions.
Effect: The failure to establish internal controls could have enabled noncompliance to go undetected. If
vendors would have been suspended or debarred, the failure to comply with the grant agreement and the
compliance requirement could have resulted in the loss of federal funds to the City.
Questioned costs: There are no questioned costs.
Context: In a sample of five vendors with aggregate disbursements for FY2023 above the $25,000 covered
transaction threshold, Crowe noted for each selection that the City had not completed a check for
suspension and debarment nor had had they obtained a contract clause from the vendor/service provider
certifying that they were not suspended and/or debarred.
Identification as a repeat finding, if applicable: Yes, finding 2022-004 in the prior year report.
Recommendation: We recommend that the City establish and implement control procedures to ensure
compliance with the grant agreement and the Procurement and Suspension and Debarment compliance
requirement. This should include ensuring suspension and debarment checks are performed and
documented prior to entering into the transaction.
Views of responsible officials and planned corrective actions: Management acknowledges the
finding. See management’s corrective action plan attached to this audit report.