Audit 363616

FY End
2024-06-30
Total Expended
$6.14M
Findings
4
Programs
17
Organization: City of Clinton, Iowa (IA)
Year: 2024 Accepted: 2025-08-04

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
572479 2024-005 Significant Deficiency Yes L
572480 2024-006 Significant Deficiency Yes L
1148921 2024-005 Significant Deficiency Yes L
1148922 2024-006 Significant Deficiency Yes L

Contacts

Name Title Type
EK1QTBKL34T9 Anita Dalton Auditee
5632422144 Alexander Kawamura Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: Expenditures reported on the schedule are reported on the accrual or modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures of federal awards are recognized in the accounting period when the liability is incurred and has met the eligibility criteria of the federal grant. Revenue from federal awards is recognized when the City has done everything necessary to establish its right to the revenue. In the governmental funds, revenue from federal grants is recognized when the revenue is both measureable and available. In proprietary funds, revenue from federal grants is recognized when it is earned. Pass-through entity identifying numbers are presented where available. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimus cost rate. The accompanying schedule of expenditures of federal awards (schedule) includes the federal grant activity of the City under programs of the federal government for the year ended June 30, 2024. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the schedule presents only a selected portion of the operations of the City, it is not intended to and does not present the financial position, changes in financial position or cash flows of the entity.
Title: Summary of Significant Accounting Policies Accounting Policies: Expenditures reported on the schedule are reported on the accrual or modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures of federal awards are recognized in the accounting period when the liability is incurred and has met the eligibility criteria of the federal grant. Revenue from federal awards is recognized when the City has done everything necessary to establish its right to the revenue. In the governmental funds, revenue from federal grants is recognized when the revenue is both measureable and available. In proprietary funds, revenue from federal grants is recognized when it is earned. Pass-through entity identifying numbers are presented where available. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimus cost rate. Expenditures reported on the schedule are reported on the accrual or modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures of federal awards are recognized in the accounting period when the liability is incurred and has met the eligibility criteria of the federal grant. Revenue from federal awards is recognized when the City has done everything necessary to establish its right to the revenue. In the governmental funds, revenue from federal grants is recognized when the revenue is both measureable and available. In proprietary funds, revenue from federal grants is recognized when it is earned. Pass-through entity identifying numbers are presented where available.
Title: Indirect Cost Rate Accounting Policies: Expenditures reported on the schedule are reported on the accrual or modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures of federal awards are recognized in the accounting period when the liability is incurred and has met the eligibility criteria of the federal grant. Revenue from federal awards is recognized when the City has done everything necessary to establish its right to the revenue. In the governmental funds, revenue from federal grants is recognized when the revenue is both measureable and available. In proprietary funds, revenue from federal grants is recognized when it is earned. Pass-through entity identifying numbers are presented where available. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimus cost rate. The City has not elected to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance.

Finding Details

Compliance Monitoring Criteria – The City entered into an agreement with East Central Intergovernmental Association (ECIA) to administer the Lead-Based Paint Hazard Control in Privately-Owned Housing grant (LBA). The agreement requires ECIA identify applicable federal and state laws and regulations and assist in complying with federal and state requirements. The agreement also requires ECIA monitor and evaluate the project progress to facilitate compliance with applicable federal and state laws and regulations. Condition – As the primary recipient of the LBA grant, the City is responsible to ensure compliance with the requirements of the Uniform Guidance. ECIA monitored the LBA grant to ensure compliance with the requirements of the Uniform Guidance. However, the City did not maintain documentation indicating eligibility, procurement and allowable payroll cost requirements were met. Cause – Although the City contracted with ECIA to administer the grant, the City is the grant recipient and, accordingly, is responsible for ensuring compliance. The City was unaware it retained this responsibility. Effect – The City is not properly monitoring ECIA to ensure compliance with the requirements of the Uniform Guidance. Noncompliance with the requirements of the Uniform Guidance could result in the loss and refunding of grant funds. Recommendation – The City should maintain and review documentation to ensure applicable compliance requirements have been met. The review should be evidenced by the initials or signature of the reviewer and the date of the review. Response and Corrective Action Planned – The City will begin to request that ALL supporting documents of an ECIA claim accompanies the claim. This will include (but is not limited to) the contractor invoices, time analysis worksheets for ECIA personnel being charged to the grant and reporting from ECIA’s tracking systems. In addition to those supporting documents, the City is already requesting ECIA’s yearly audit report but will implement a procedure to sign off that it was reviewed. Conclusion – Response accepted.
Federal Funding Accountability and Transparency Act Reports Criteria – The Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of the Government Funding Transparency Act of 2008 (Pub. L. No. 110-252), requires prime awardees to submit reports regarding their first-tier subawards to the Federal funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports are due for all applicable subrecipient grants by the end of the month subsequent to the month the grants were awarded. Condition – The City did not report subaward information for one subrecipient as required by the Federal Funding Accountability and Transparency Act. Cause – Although the City contracted with ECIA to administer the grant, the City remained the grant recipient and, accordingly, retained responsibility for ensuring compliance was met. The City was unaware it retained this responsibility. Effect – The City is not reporting the required subaward information to ensure compliance with the requirements of the Uniform Guidance. Recommendation – The City should establish policies and procedures to ensure reports are submitted in accordance with the Federal Funding Accountability and Transparency Act. Response and Corrective Action Planned – The City tried to report this fiscal year but was unable to find out where to report these awards. The City will do further investigation as to where to properly report these awards. Conclusion – Response accepted.
Compliance Monitoring Criteria – The City entered into an agreement with East Central Intergovernmental Association (ECIA) to administer the Lead-Based Paint Hazard Control in Privately-Owned Housing grant (LBA). The agreement requires ECIA identify applicable federal and state laws and regulations and assist in complying with federal and state requirements. The agreement also requires ECIA monitor and evaluate the project progress to facilitate compliance with applicable federal and state laws and regulations. Condition – As the primary recipient of the LBA grant, the City is responsible to ensure compliance with the requirements of the Uniform Guidance. ECIA monitored the LBA grant to ensure compliance with the requirements of the Uniform Guidance. However, the City did not maintain documentation indicating eligibility, procurement and allowable payroll cost requirements were met. Cause – Although the City contracted with ECIA to administer the grant, the City is the grant recipient and, accordingly, is responsible for ensuring compliance. The City was unaware it retained this responsibility. Effect – The City is not properly monitoring ECIA to ensure compliance with the requirements of the Uniform Guidance. Noncompliance with the requirements of the Uniform Guidance could result in the loss and refunding of grant funds. Recommendation – The City should maintain and review documentation to ensure applicable compliance requirements have been met. The review should be evidenced by the initials or signature of the reviewer and the date of the review. Response and Corrective Action Planned – The City will begin to request that ALL supporting documents of an ECIA claim accompanies the claim. This will include (but is not limited to) the contractor invoices, time analysis worksheets for ECIA personnel being charged to the grant and reporting from ECIA’s tracking systems. In addition to those supporting documents, the City is already requesting ECIA’s yearly audit report but will implement a procedure to sign off that it was reviewed. Conclusion – Response accepted.
Federal Funding Accountability and Transparency Act Reports Criteria – The Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of the Government Funding Transparency Act of 2008 (Pub. L. No. 110-252), requires prime awardees to submit reports regarding their first-tier subawards to the Federal funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports are due for all applicable subrecipient grants by the end of the month subsequent to the month the grants were awarded. Condition – The City did not report subaward information for one subrecipient as required by the Federal Funding Accountability and Transparency Act. Cause – Although the City contracted with ECIA to administer the grant, the City remained the grant recipient and, accordingly, retained responsibility for ensuring compliance was met. The City was unaware it retained this responsibility. Effect – The City is not reporting the required subaward information to ensure compliance with the requirements of the Uniform Guidance. Recommendation – The City should establish policies and procedures to ensure reports are submitted in accordance with the Federal Funding Accountability and Transparency Act. Response and Corrective Action Planned – The City tried to report this fiscal year but was unable to find out where to report these awards. The City will do further investigation as to where to properly report these awards. Conclusion – Response accepted.