Audit 398969

Finding Number: 2025-001 Federal Program: Housing Opportunities for Persons with Aids, Ending the HIV Epidemic: A Plan for America Federal Award Identification Number: OHH22F003; OHH23F003; OHH24F003; UT833926 Assistance Listing Number (ALN): 14.241, 93.686 Federal Awarding Agency: Department of Housing and Urban Development, Department of Health and Human Services Compliance Requirement: Reporting Pass-through Entity: Direct Award Repeat Finding: Yes (AL 14.241) and No (AL 93.686) Prior Audit Finding Number: 2024-003 (AL 14.241) Material Weakness and Material Noncompliance – Federal Funding Accountability and Transparency Act Reporting Criteria The Federal Funding Accountability and Transparency Act (Transparency Act – “FFATA”), as codified in 2 CFR Part 170, requires prime recipients of Federal awards to report first-tier subawards of $30,000 or more in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and, effective March 8, 2025, the System for Award Management website (SAM.gov). Recipients must report these subawards by the end of the month following the month in which the obligation is made. As a direct recipient of Federal funding, the City of Columbus is responsible for ensuring subaward information is reported completely, accurately, and timely in accordance with these requirements. Management is also responsible for establishing and maintaining internal controls to ensure compliance with applicable laws and regulations. Condition During the audit period, the City disbursed approximately $1.58 million under AL #14.241 (Housing Opportunities for Persons with AIDS – “HOPWA”) to four first-tier subrecipients, each exceeding the $30,000 reporting threshold. However, none of these subawards were reported in FSRS/SAM.gov as required. Reporting responsibilities were assigned to the Department of Finance and Management until a new policy, effective May 1, 2025, was put into place transitioning FFATA reporting responsibility for the HOPWA program to the Department of Development. All subawards under this program were executed prior to May 1, 2025. During the audit period, the City disbursed approximately $1.75 million under AL #93.686 (Ending the HIV Epidemic: A Plan for America) to eight first-tier subrecipients, each exceeding the $30,000 reporting threshold, and two of which were selected for testing. Neither of the subawards tested were reported in FSRS/SAM.gov as required. Reporting responsibilities are assigned to Columbus Public Health, which did not submit the required data for this program. Cause The Departments lacked adequate internal controls over the preparation, review, and submission of FSRS/SAM.gov reports, resulting in the omission of required subaward reporting. Effect Failure to report subawards as required results in noncompliance with Federal transparency requirements. This increases the risk of incomplete or inaccurate public reporting and may lead to potential sanctions, including reduced or withheld Federal funding. Additionally, users of Transparency Act data may rely on incomplete information. Recommendation The City should strengthen internal controls over the FSRS/SAM.gov reporting process to ensure all applicable subawards are reported timely and accurately. This should include procedures to identify reportable subawards, assign clear reporting responsibilities, and perform supervisory review of submissions. The City should also implement a reconciliation process between internal records and FSRS/SAM.gov data and periodically evaluate these controls to ensure ongoing compliance with Federal requirements. Officials’ Response: Refer to the Corrective Action Plan.

Finding Number: 2025-002 Federal Program: Ending the HIV Epidemic: A Plan for America Federal Award Identification Number: UT833926 Assistance Listing Number (ALN): 93.686 Federal Awarding Agency: Department of Health & Human Services Compliance Requirement: Activities Allowed or Unallowed & Allowable Costs/Cost Principles Pass-through Entity: Direct Award Repeat Finding: No Prior Audit Finding Number: N/A Material Weakness – Payroll Approvals Criteria 2 CFR § 300.106 gives regulatory effect to U.S. Department of Health & Human Services for 2 CFR § 200.303(a), which requires non-Federal entities to establish and maintain effective internal control over Federal awards. These controls must provide reasonable assurance that awards are managed in compliance with applicable statutes, regulations, and award terms, and should align with standards issued by the Government Accountability Office or the Committee of Sponsoring Organizations of the Treadway Commission. Additionally, 2 CFR § 200.430(g)(1)(i) requires that charges to Federal awards for salaries and wages be supported by records that accurately reflect the work performed and are backed by a system of internal controls ensuring the charges are accurate, allowable, and properly allocated. The City of Columbus’ Department of Public Health policy titled, “Staff Timekeeping for Grant Funded Positions,” Part I, requires all grant funded staff to complete timesheets reflecting total hours worked and grant-related hours. Section D, specifically, requires that timesheets must be signed by and submitted for approval on the Tuesday following the end of a pay period. Timesheets submitted for approval must be approved by either the employees’ supervisor or the director of the program by the Thursday following the end of a pay period. Condition Although the City has established policies consistent with Federal requirements, supervisory review of timesheets was not performed timely in all instances. During testing of the payroll records under AL #93.686 (Ending the HIV Epidemic: A Plan for America), none of the 40 timesheets tested were reviewed within the required timeframe referenced in the Criteria section. Cause Supervisory personnel did not consistently follow established procedures for timely review and approval of timesheets. Effect Failure to follow the established internal control policy and ensuring all timesheets are appropriately reviewed and approved by a knowledgeable supervisor, within the required timeframe referenced in the Criteria section, could result in unallowable costs being allocated to a federal program and could ultimately result in noncompliance and/or a questioned cost. Recommendation The City should reinforce its existing policies with supervisory staff and implement additional procedures, if necessary, to ensure timesheets are reviewed and approved within the required timeframe prior to charging costs to Federal programs. Officials’ Response: Refer to the Corrective Action Plan.

Finding Number: 2025-003 Federal Program: Coronavirus State and Local Fiscal Recovery Funds Federal Award Identification Number: 31-6400223 Assistance Listing Number (ALN): 21.027 Federal Awarding Agency: Department of Treasury Compliance Requirement: Subrecipient Monitoring Pass-through Entity: Direct Award Repeat Finding: No Prior Audit Finding Number: N/A Significant Deficiency and Noncompliance – Subrecipient Monitoring Criteria Under 2 CFR § 200.332, pass-through entities are required to monitor the activities of subrecipients to ensure compliance with applicable federal statutes, regulations, and the terms and conditions of the subaward. This includes reviewing financial and performance reports, following up on deficiencies, and ensuring corrective action is taken. Condition During our testing of three subrecipient agreements, we noted that the City did not perform or document monitoring procedures for one subrecipient. Specifically, there was no evidence of review of financial reports, site visits, or other oversight activities for this subrecipient during the audit period. This condition only applies to subawards below a certain threshold, of which, the subrecipient activity is immaterial. For subawards above that threshold, the City utilizes a third-party consulting firm to perform subrecipient monitoring. The subawards tested that were monitored by the consulting firm did not indicate noncompliance. Cause The City does not have a consistent process in place to ensure all subrecipients are monitored in accordance with federal requirements. In this instance, monitoring procedures were either not performed or not documented. Effect Without proper monitoring, the City cannot ensure that subrecipients are using funds in compliance with program requirements. This increases the risk of noncompliance, improper use of funds, and undetected errors or irregularities. Recommendation We recommend the City implement and consistently follow formal subrecipient monitoring procedures. These should include documenting reviews of financial and performance reports, performing risk-based monitoring activities, and maintaining evidence of oversight for each subrecipient. Officials’ Response: See Corrective Action Plan.