Audit 385059

Identification of the Federal Program: Federal Agency and Program Name Assistance Listing # COVID-19 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) (FEMA) U.S. Department of Homeland Security Pass through grantor: Virginia Department of Emergency Management Pass through award number: 4512DR-VA Award Period: 1/21/2020 – 6/30/2022 97.036 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR 200.303 requires that a non-Federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.403(h) states: “Administrative closeout costs may be incurred until the due date of the final report(s). If incurred, these costs must be liquidated prior to the due date of the final report(s) and charged to the final budget period of the award unless otherwise specified by the Federal agency. All other costs must be incurred during the approved budget period. At its discretion, the Federal agency is authorized to waive prior written approvals to carry forward unobligated balances to subsequent budget periods. See § 200.308(g)(3).” Condition: The Authority did not validate the accuracy of the cost incurred dates and identify expenditures that were incurred outside of the period of performance related to assistance listing 97.036 – COVID-19 – Disaster Grants – Public Assistances (Presidentially Declared Disasters) (FEMA) prior to submission of the non-federal entity’s project worksheet. Cause: The Authority did not have sufficient internal controls to ensure that accuracy of the cost incurred dates or expenditures were incurred within the period of performance prior to submission of the non-federal entity’s project worksheet. Effect or Potential Effect: The Authority may inappropriately obtain funding for unallowable expenses or costs incurred outside the period of performance as a result of the reporting and verification of the completeness and accuracy of the cost incurred dates and expenditures included within the submission was not sufficient. Questioned Costs: $104,434 – represents the total payroll expenditures incurred after the end of the period of performance. Context: We identified $104,434 of payroll expenditures included in the submission of two force labor FEMA projects, resulting in duplicate costs being submitted to FEMA. The $104,434 was incorrectly included in the project that ended June 30, 2022 and was appropriately included in the project that began July 1, 2022. The costs in question are the payroll expenses from the second week of the pay period (June 26, 2022 through July 9, 2022) incurred after the end of the period of performance. The total obligation of the project worksheet that had the duplicate costs was $2,278,390. Management corrected the duplicated amount of the federal expenditures reported on the Schedule, in which total FEMA expenditures are $31,901,782 for the year ended June 30, 2025. The duplicate costs represent 4.6% of the related project and approximately 0.3% of total FEMA expenditures for the fiscal year. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: The Authority’s policy and procedures should be designed to strengthen the internal controls over the review of the submissions to ensure accurate reporting as required by the Uniform Guidance. Views of Responsible Officials: There is no disagreement with the audit finding and the Authority has developed a plan to correct the finding.