Audit 378547

Condition: The City did not provide proof of submission of Equitable Sharing Agreement and Certification (ESAC), records of tangible assets or real property acquired through the program and inventory logs for items purchased with program funds. Criteria or Specific Requirement: These documents are required per the Guide to Equitable Sharing for State, Local, and Tribal Law Enforcement Agencies and the 2024 Compliance Supplement. Effect or Potential Effect: The City did not demonstrate compliance with requirements of the Federal Equitable Sharing – Justice Program. Cause: The cause is not readily determinable. The documentation was not provided. Context: Audit requests for the Equitable Sharing Program included testing of compliance requirements material to the program. While sufficient documentation was provided to support expenditures, the City did not provide any of the other required documentation. As a result, testing of compliance requirements was limited. Questioned Costs: Not applicable. Recommendation: The City should: (1) Implement procedures to ensure all required program documentation is maintained in a central, accessible location. (2) Assign responsibility to a designated compliance officer or grants administrator to track and provide program documents. (3) Periodically review documentation requirements to ensure continued compliance with the Guide to Equitable Sharing and 2 CFR Part 200. Views of Responsible Officials of the City (unaudited): Planned Action: To address the internal control weakness and noncompliance with federal program requirements, the City will implement the following corrective measures: 1. Centralized Document Management: Create a centralized digital and physical repository to maintain all documentation related to the Equitable Sharing Program, including the Equitable Sharing Agreement and Certification (ESAC), records of tangible and real property acquired and inventory logs of items purchased with program funds; ensure access is controlled but available to authorized personnel for audit and compliance purposes. 2. Assignment of Compliance Oversight: Designate a Fiscal Officer or Grants Administrator responsible for overseeing and maintaining compliance with the Federal Equitable Sharing Program; responsibilities will include submission of required certifications, tracking property acquired, maintaining inventory records, and responding to audit or federal requests. 3. Periodic Compliance Reviews: Establish a schedule (i.e. monthly) for internal reviews of documentation to ensure ongoing compliance with the Guide to Equitable Sharing for State, Local, and Tribal Law Enforcement Agencies, the 2024 Compliance Supplement and 2 CFR Part 200 Uniform Guidance; review procedures to verify that ESACs are submitted on time and that all purchases and inventory are accurately tracked and recorded. 4. Training and Internal Controls: Provide annual training to relevant departments on compliance requirements for federal grant programs, particularly those involving equipment and real property management; update internal grant management policies to reflect the specific requirements of the Equitable Sharing Program. Anticipated Completion Date: Immediate action has been requested. Contact Person Responsible for Corrective Action: Director of Public Safety or the assigned Program Manager in the Department of Public Safety Compliance Oversight & Advisement: Silendra Baijnauth, Director of Management & Budget to monitor expenditures; La Vivanan Webb, Director of Grant Administration & Compliance to provide access to the AmpliFund platform which is a tool for other City offices to use to manage their grant compliance and reporting. Additional Note: In light of the audit finding, the Department of Finance has restricted the Department of Public Safety from making any additional encumbrances against this account until the audit finding is addressed and reporting requirements are met.