Audit 398516

Reviews of Grant Reports U.S. Department of Treasury ALN 21.027 - COVID 19 Coronavirus State and Local Fiscal Recovery Funds Contract No. Y5177 2021 Funding Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. Reports should be subject to independent review to verify completeness, validity and timeliness of submission. Condition: There was no documented review by an independent individual for the reports submitted to the US Treasury department prior to submittal. Cause: The City did not have a process in place to document the review of reports to the US Treasury was prior to submittal. Effect: Reports submitted to the Florida Department of State may be incomplete, include errors, or be submitted late. Perspective: There was no evidence of review provided for the reports submitted during Fiscal Year 2025. Questioned Costs: None, reported finding is a deficiency in internal control. Recommendation: The City should have controls in place to ensure all reports are reviewed prior to submittal and the review is documented. Management Response: Management agrees with the finding. Management will implement procedures to document independent review of all reports submitted to the U.S. Treasury to ensure completeness, accuracy, and timeliness.

Compliance over Negotiation Process U.S. Department of Treasury ALN 21.027 - COVID 19 Coronavirus State and Local Fiscal Recovery Funds Contract No. Y5177 2021 Funding Criteria: 2 CFR 200.11 and 49 CFR 24 govern real property acquisition with Federal funds. 49 CFR 24.9 requires agencies to maintain adequate records of its acquisition and displacement activities in sufficient detail to demonstrate compliance with the Federal code. Records shall be retained for at least three years after each owner of the property receives final payment or in accordance with grantor regulations, whichever is later. Condition: During our audit procedures it was noted by City staff that there was insufficient communication to the seller regarding eminent domain and that this power would not be used to acquire the property if negotiations fail. Cause: During the course of our audit procedures, City staff noted that federal funded real property acquisitions were not conducted in accordance with 2 CFR 200 and 49 CFR 24 as the City’s control for procurement of real property did not identify the City’s procedures were not completed in accordance with 2 CFR 200 and 49 CFR 24. Effect: Without adequate controls over the documentation of communications with sellers, the City may not be in compliance with Federal code or able to demonstrate compliance with Federal code. Perspective: The City did not have proper controls in place to ensure the City was acquiring property in compliance with 2 CFR 200 and 49 CFR 24. Questioned Costs: None, reported finding is a deficiency in internal control. Recommendation: The City should review the documentation sent to the seller during the procurement process to ensure the City is providing all necessary documentation to the seller according to 2 CFR 200 and 49 CFR 24. Management Response: Management agrees with the finding. The issue resulted from procedures not fully aligning with federal requirements for real property acquisition documentation and communication. Management will implement procedures to ensure all required communications and documentation are provided and retained in accordance with 2 CFR 200 and 49 CFR 24, including clear communication to sellers and proper recordkeeping to demonstrate compliance.