U.S. Department of Housing and Urban Development Community Block Development Grants/Entitlement Cluster - 14.218 Multiple Awards and Award Years including COVID-19 funding Criteria or Specific Requirement – Reporting and Significant Deficiency 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). Condition: During our test work over the Community Block Development Grants/Entitlement Cluster, we noted the Unified Government did not report to the FSRS. Cause: The Unified Government's controls to ensure required report submissions occur were not operating effectively. Effect: The Unified Government did not submit required reports to the FSRS. Questioned Costs – None noted. Context: Two of the Unified Government's first-tier subrecipients of the Community Block Development Grants/Entitlement Cluster exceeded $30,000 in funding. Neither of these subawards were submitted to the FSRS. Identification of Prior Year Finding: 2023-014 Recommendation: We recommend that the Unified Government implement a process to ensure required report submissions to the FSRS occur. Views of Responsible Official and Planned Corrective Actions: We agree with the finding. See management corrective action plan.
U.S. Department of Housing and Urban Development Community Block Development Grants/Entitlement Cluster - 14.218 Multiple Awards and Award Years including COVID-19 funding Criteria or Specific Requirement – Reporting and Significant Deficiency The Quarterly Cash on Hand report must be submitted to the respective field office within 30 days after the end of the quarterly reporting period. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our test work over the Community Block Development Grants/Entitlement Cluster, we noted the Unified Government submitted two of the quarterly reports for the CDBG Entitlement program after the 30 day deadline. Cause: The Unified Government's controls to ensure required report submissions occur were not operating effectively. Effect: Required reports were not submitted timely. Questioned Costs – None noted. Context: Out of two quarters selected for testing, one quarters reports were submitted past the 30 day deadline. CDBG Cash on Hand Report Due Quarterly (January 1, 2024-March 31, 2024) and CDBG-CV Cash on Hand Report Due Quarterly (January 1, 2024-March 31, 2024) were submitted on July 24, 2024, 85 days past the 30 day due date. Identification of Prior Year Finding: N/A Recommendation: We recommend that the Unified Government implement a process to ensure reports are submitted by the required due date. Views of Responsible Official and Planned Corrective Actions: We agree with the finding. See management corrective action plan.
U.S. Department of Treasury - direct funding COVID 19 - Coronavirus State and Local Fiscal Recovery Funds - 21.027 Criteria or Specific Requirement: Procurement and Significant Deficiency In accordance with 2 CFR 200.318, recipients and subrecipients must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including acquisition of property and services. These documented procurement procedures must be consistent with State, local and tribal laws and regulations and the standards identified in 2 CFR 200.317 through 2 CFR 200.327. Condition: During our test work over the Coronavirus State and Local Fiscal Recovery grant, we noted the Unified Government did not perform procurement procedures on two of its vendor contracts. Cause: The vendors identified were granted a non-competitive procurement under national emergency conditions due to the effects of COVID-19. However, the vendor was utilized again after the national emergency period and the Unified Government's procurement policy should have been followed at this time, but was not. Effect: Federal funds could be paid to entities outside of the Unified Government's procurement policy. Questioned Costs - $15,000 - This represents the total purchase for the two vendors which did not follow the Unified Government's formal procurement procedures. These charges were included in the direct award received from the U.S. Department of Treasury. Context: For 21.027, there were 50 vendors receiving a total of $10,862,254 subject to procurement requirements. Of those 50, a sample of thirteen vendors receiving a total of $1,523,729 were selected for testing. Two of the thirteen vendors selected for testing did not undergo the Unified Government's formal procurement procedures. The sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: 2023-011 Recommendation: We recommend that the Unified Government communicate to all departments that purchases using federal funds follow the procurement policy procedures prior to purchase and the procurement department provide training on the requirements to properly document that the procedures are completed. View of Responsible Official and Planned Corrective Actions: We agree with the finding. See management corrective action plan.
U.S. Department of Health and Human Services, passed through Kansas Department of Aging and Disability Services Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2301KSOASS ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2301KSOAHD ALN 93.053 - Nutrition Services Incentive Program - 2301KSOAHD Criteria or Specific Requirement: Suspension and Debarment and Significant Deficiency In accordance with 2 CFR 200.214, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Suspension and debarment checks were not completed for the subrecipient that received federal funds. Cause: For the Unified Government, this is typically included in the contracts, but was not included in the subrecipient contracts for this program and the Unified Government did not have another means of validating suspension and debarment. Effect: Federal funds could be paid to entities that are suspended or debarred. Questioned Costs: None noted. Context: Only one subrecipient received pass-through funding from the Unified Government. The single subrecipient under ALN 93.044, 93.045 and 93.053, receiving approximately $428,000, was not evaluated for suspension and debarment. It was noted after subsequent check, that the subrecipient was not suspended or debarred. Identification of Prior Year Finding: 2023-006, 2022-007, 2021-005, 2020-002 Recommendation: Policies and procedures should be modified to ensure that suspension and debarment checks are performed on vendors and subrecipients alike prior to making purchases with federal funds. When newly established programs include subrecipients, we also recommend the contracts include suspension and debarment language. View of Responsible Official and Planned Corrective Actions: We agree with the finding. See management corrective action plan.