Audit 399021

2025-006 FEMA Grants (Repeat Finding 2023-018, 2024-004) CFDA Title: Disaster Grants – Public Assistance (Presidentially Declared Disasters) CFDA Number: 97.036 Federal Award Number: FEMA-4655-DR-MT Federal Agency: Department of Homeland Security Pass-through Entity: Montana Department of Emergency Services Condition: Program expenditures for disaster projects under the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were not separately identified in the County’s accounting records by Project Worksheet (PW). The County’s general ledger does not distinguish expenditures related to these PWs from other federal and non-federal expenditures recorded in the Disaster Fund. Context: Through inquiry and testing, we identified that the County does not have a process or system in place to record project-level expenditures or to reconcile reimbursement requests to the accounting system. As a result, expenditures are accumulated at a fund level rather than by individual project. Criteria: Federal grant compliance requirements under the Disaster Grants – Public Assistance program require subrecipients to establish an accounting system capable of tracking expenditures by individual project (PW) to ensure that only allowable and properly supported costs are submitted for reimbursement and reported accurately. Questioned Costs: None Effect: The County is not in compliance with the direct and material compliance requirements of the Disaster Grants – Public Assistance program. The accounting system does not distinguish eligible costs by specific project or segregate federal expenditures from locally funded expenditures, increasing the risk of submitting unsupported or ineligible costs. Cause: The County has not implemented internal control policies and procedures to (1) ensure that federal program expenditures are separately identified and tracked by project in the general ledger, and (2) require reconciliation of reimbursement requests to the underlying accounting records to verify completeness and accuracy. Recommendation: 1. The County should establish policies and procedures to ensure that compliance requirements, including special tests and provisions, are identified upon receipt of a new grant and that an appropriate internal control structure is implemented to ensure compliance. 2. The County should establish and implement internal control policies and procedures to ensure that all federal program expenditures are separately identified in the general ledger from non-federal expenditures, and that costs related to this grant are tracked by project (e.g., by PW or project code). This may include revising the chart of accounts or implementing grant/project coding within the financial system. 3. The County should implement procedures to periodically reconcile project-level general ledger activity to reimbursement requests and supporting documentation, and to review such reconciliations for completeness, accuracy, and allowability prior to submission.