Audit 40444

FY End
2022-06-30
Total Expended
$264.53M
Findings
2
Programs
40
Organization: City of San Diego (CA)
Year: 2022 Accepted: 2023-03-29

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
42214 2022-001 Significant Deficiency - P
618656 2022-001 Significant Deficiency - P

Programs

ALN Program Spent Major Findings
66.958 Water Infrastructure Finance and Innovation (wifia) $74.39M - 0
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $19.17M Yes 1
14.218 Community Development Block Grants/entitlement Grants $7.46M - 0
14.239 Home Investment Partnerships Program $5.81M - 0
15.504 Title Xvi Water Reclamation and Reuse Program $3.52M - 0
11.307 Economic Adjustment Assistance $2.00M Yes 0
81.041 Arra State Energy Program $1.28M - 0
11.307 Covid-19 Economic Adjustment Assistance $1.24M Yes 0
32.009 Covid-19 Emergency Connectivity Fund Program $1.22M - 0
14.218 Covid-19 Community Development Block Grants/entitlement Grants $1.13M - 0
97.025 National Urban Search and Rescue (us&r) Response System $985,795 - 0
97.056 Port Security Grant Program $750,000 - 0
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $646,004 - 0
97.044 Assistance to Firefighters Grant $629,508 - 0
21.016 Equitable Sharing $622,061 - 0
14.231 Emergency Solutions Grant Program $617,405 - 0
16.922 Equitable Sharing Program $515,229 - 0
20.600 State and Community Highway Safety $447,466 - 0
16.738 Edward Byrne Memorial Justice Assistance Grant Program $410,533 - 0
97.067 Homeland Security Grant Program $361,668 - 0
20.205 Highway Planning and Construction $320,522 Yes 0
16.543 Missing Children's Assistance $296,214 - 0
14.231 Covid-19 Emergency Solutions Grant Program $275,047 - 0
20.106 Airport Improvement Program $245,441 - 0
16.741 Dna Backlog Reduction Program $234,843 - 0
20.616 National Priority Safety Programs $204,787 - 0
45.310 Grants to States $121,912 - 0
97.042 Emergency Management Performance Grants $93,270 - 0
97.041 National Dam Safety Program $87,056 - 0
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $81,319 - 0
97.012 Boating Safety Financial Assistance $50,446 - 0
12.003 Community Economic Adjustment Assistance for Responding to Threats to the Resilience of A Military Installation (b) $45,897 - 0
16.609 Project Safe Neighborhoods $27,097 - 0
66.468 Capitalization Grants for Drinking Water State Revolving Funds $20,571 - 0
45.129 Promotion of the Humanities_federal/state Partnership $20,000 - 0
16.301 Law Enforcement Assistance_fbi Crime Laboratory Support $17,180 - 0
15.904 Historic Preservation Fund Grants-in-Aid $13,134 - 0
16.525 Grants to Reduce Domestic Violence, Dating Violence, Sexual Assault, and Stalking on Campus $1,212 - 0
16.734 Special Data Collections and Statistical Studies $29 - 0
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $-10,819 - 0

Contacts

Name Title Type
L4FACR9F6GK7 Jeffrey Peelle Auditee
6192366712 Linda Hurley Auditor
No contacts on file

Notes to SEFA

Title: WATER INFRASTRUCTURE FINANCE AND INNOVATION (WIFIA) LOAN AGREEMENT Accounting Policies: Expenditures reported in the accompanying Schedule are presented using the modified accrual basis of accounting for grants accounted for in the governmental fund types and the accrual basis of accounting for grants accounted for in the proprietary fund types, as described in Note 1.c. in the notes to the Citys basic financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown in the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. The negative amount of $10,819 reported for Assistance Listing Number (ALN) 97.036, Disaster Grants Public Assistance (Presidentially Declared disasters) grant number FEMA-4305-DR-CA 073-66000 represents a refund to the funding agency due to the funding agencys obligation amount to the City being changed. De Minimis Rate Used: Both Rate Explanation: The City elected not to use the 10 percent de minims indirect cost rate allowed under the Uniform Guidance, except for the Homeland Security Grant Program passed through the California Governors Office of Emergency Services (ALN 97.067, Homeland Security Grant Program grant numbers 2018-0054/0073-66000, 2019-0035/0073-66000 and 2020-0095/073-66000). In November 2018, the City and the U.S. Environmental Protection Agency (USEPA) executed the WIFIA Program loan in the amount of up to $614,000,000 payable from the Net System Revenues of the Water Utility Fund for the first phase of the Pure Water project. In September 2020, the City and USEPA executed another agreement to replace the previous agreement, with a majority of the terms staying exactly the same, but with a lower interest rate of 1.29%. Construction is anticipated to be completed in March 2027 with annual principal and interest payments on this loan commencing in August, 2024 through August, 2057. For the fiscal year ended June 30, 2022, the City received and expended $74,392,873 from the USEPA related to ALN 66.958. The outstanding loan balance as of June 30, 2022 is $83,951,866.
Title: Basis of Presentation Accounting Policies: Expenditures reported in the accompanying Schedule are presented using the modified accrual basis of accounting for grants accounted for in the governmental fund types and the accrual basis of accounting for grants accounted for in the proprietary fund types, as described in Note 1.c. in the notes to the Citys basic financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown in the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. The negative amount of $10,819 reported for Assistance Listing Number (ALN) 97.036, Disaster Grants Public Assistance (Presidentially Declared disasters) grant number FEMA-4305-DR-CA 073-66000 represents a refund to the funding agency due to the funding agencys obligation amount to the City being changed. De Minimis Rate Used: Both Rate Explanation: The City elected not to use the 10 percent de minims indirect cost rate allowed under the Uniform Guidance, except for the Homeland Security Grant Program passed through the California Governors Office of Emergency Services (ALN 97.067, Homeland Security Grant Program grant numbers 2018-0054/0073-66000, 2019-0035/0073-66000 and 2020-0095/073-66000). The accompanying Schedule of Expenditures of Federal Awards (Schedule) presents the activity of all federal award programs of the City of San Diego, California (City). The Schedule excludes the federal award programs of the San Diego Housing Commission (refer to Note 5). Federal awards received directly from federal agencies as well as federal awards passed through other nonfederal agencies, primarily the State of California (State), are included in the Schedule. The Citys reporting entity is defined in Note 1.a. in the notes to the Citys basic financial statements. Because the Schedule presents only a selected portion of the operations of the City, it is not intended to and does not, present the financial position of the City. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in this Schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements.
Title: Assistance Listing Numbers Accounting Policies: Expenditures reported in the accompanying Schedule are presented using the modified accrual basis of accounting for grants accounted for in the governmental fund types and the accrual basis of accounting for grants accounted for in the proprietary fund types, as described in Note 1.c. in the notes to the Citys basic financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown in the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. The negative amount of $10,819 reported for Assistance Listing Number (ALN) 97.036, Disaster Grants Public Assistance (Presidentially Declared disasters) grant number FEMA-4305-DR-CA 073-66000 represents a refund to the funding agency due to the funding agencys obligation amount to the City being changed. De Minimis Rate Used: Both Rate Explanation: The City elected not to use the 10 percent de minims indirect cost rate allowed under the Uniform Guidance, except for the Homeland Security Grant Program passed through the California Governors Office of Emergency Services (ALN 97.067, Homeland Security Grant Program grant numbers 2018-0054/0073-66000, 2019-0035/0073-66000 and 2020-0095/073-66000). The ALNs included in the accompanying Schedule were determined based on the federal program name, review of grant contract information, and the Office of Management and Budgets Catalog of Assistance Listings.
Title: SAN DIEGO HOUSING COMMISSION (DISCRETELY PRESENTED COMPONENT UNIT) FEDERAL Accounting Policies: Expenditures reported in the accompanying Schedule are presented using the modified accrual basis of accounting for grants accounted for in the governmental fund types and the accrual basis of accounting for grants accounted for in the proprietary fund types, as described in Note 1.c. in the notes to the Citys basic financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown in the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. The negative amount of $10,819 reported for Assistance Listing Number (ALN) 97.036, Disaster Grants Public Assistance (Presidentially Declared disasters) grant number FEMA-4305-DR-CA 073-66000 represents a refund to the funding agency due to the funding agencys obligation amount to the City being changed. De Minimis Rate Used: Both Rate Explanation: The City elected not to use the 10 percent de minims indirect cost rate allowed under the Uniform Guidance, except for the Homeland Security Grant Program passed through the California Governors Office of Emergency Services (ALN 97.067, Homeland Security Grant Program grant numbers 2018-0054/0073-66000, 2019-0035/0073-66000 and 2020-0095/073-66000). The San Diego Housing Commission (SDHC) federal expenditures of $460,557,905 are excluded from the Citys Schedule because the SDHC federal expenditures are separately audited by other auditors and reported in a separate Uniform Guidance report.
Title: Economic Adjustment Assistance Program (ALN 11.307) Accounting Policies: Expenditures reported in the accompanying Schedule are presented using the modified accrual basis of accounting for grants accounted for in the governmental fund types and the accrual basis of accounting for grants accounted for in the proprietary fund types, as described in Note 1.c. in the notes to the Citys basic financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown in the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. The negative amount of $10,819 reported for Assistance Listing Number (ALN) 97.036, Disaster Grants Public Assistance (Presidentially Declared disasters) grant number FEMA-4305-DR-CA 073-66000 represents a refund to the funding agency due to the funding agencys obligation amount to the City being changed. De Minimis Rate Used: Both Rate Explanation: The City elected not to use the 10 percent de minims indirect cost rate allowed under the Uniform Guidance, except for the Homeland Security Grant Program passed through the California Governors Office of Emergency Services (ALN 97.067, Homeland Security Grant Program grant numbers 2018-0054/0073-66000, 2019-0035/0073-66000 and 2020-0095/073-66000). In accordance with guidance provided by the U.S. Department of Commerce contained in the OMB Compliance Supplement, the City has reported federal award expenditures of $3,236,684 in the Schedule for the Revolving Loan Fund (RLF) Program under the Economic Adjustment Assistance program. Expenditures reported in the Schedule were calculated as follows: See Table in Notes to the SEFA.
Title: EMERGENCY RENTAL ASSISTANCE Accounting Policies: Expenditures reported in the accompanying Schedule are presented using the modified accrual basis of accounting for grants accounted for in the governmental fund types and the accrual basis of accounting for grants accounted for in the proprietary fund types, as described in Note 1.c. in the notes to the Citys basic financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown in the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. The negative amount of $10,819 reported for Assistance Listing Number (ALN) 97.036, Disaster Grants Public Assistance (Presidentially Declared disasters) grant number FEMA-4305-DR-CA 073-66000 represents a refund to the funding agency due to the funding agencys obligation amount to the City being changed. De Minimis Rate Used: Both Rate Explanation: The City elected not to use the 10 percent de minims indirect cost rate allowed under the Uniform Guidance, except for the Homeland Security Grant Program passed through the California Governors Office of Emergency Services (ALN 97.067, Homeland Security Grant Program grant numbers 2018-0054/0073-66000, 2019-0035/0073-66000 and 2020-0095/073-66000). The federal Emergency Rental Assistance (ERA) program makes funding available to assist households that are unable to pay rent or utilities due to the COVID-19 pandemic. Two separate programs have been established: ERA1 provides up to $25 billion under the Consolidated Appropriations Act, 2021, which was enacted on December 27, 2020, and ERA2 provides up to $21.55 billion under the American Rescue Plan Act of 2021, which was enacted on March 11, 2021. The City was awarded and received $108,264,545 and $121,251,842 for ERA1 and ERA2, respectively. Additionally, the City have been awarded $74,897,774 of ERA Reallocation funds passed through from the State of California.The City entered a memorandum of understanding for the administration of the COVID-19 Housing Stability Assistance Program (HSAP MOU) with the SDHC on March 2021. The City Council and the SDHC Housing Authority approved and authorized to transfer the awarded amount of the ERA programs to the SDHC to administrate the COVID-19 Housing Stability Assistance Program (HSAP Program). Upon the HSAP MOU, the SDHC is responsible for operation and oversight of the HSAP program in compliance with the HSAP Program policy and guidelines as well as the compliance requirements of the federal ERA program. Therefore, the accompanying SEFA does not contain ERA 1, ERA 2, and ERA Reallocation expenditures.
Title: FEDERAL AWARD PROGRAM EXPENDITURES BY GRANT AWARD Accounting Policies: Expenditures reported in the accompanying Schedule are presented using the modified accrual basis of accounting for grants accounted for in the governmental fund types and the accrual basis of accounting for grants accounted for in the proprietary fund types, as described in Note 1.c. in the notes to the Citys basic financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown in the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. The negative amount of $10,819 reported for Assistance Listing Number (ALN) 97.036, Disaster Grants Public Assistance (Presidentially Declared disasters) grant number FEMA-4305-DR-CA 073-66000 represents a refund to the funding agency due to the funding agencys obligation amount to the City being changed. De Minimis Rate Used: Both Rate Explanation: The City elected not to use the 10 percent de minims indirect cost rate allowed under the Uniform Guidance, except for the Homeland Security Grant Program passed through the California Governors Office of Emergency Services (ALN 97.067, Homeland Security Grant Program grant numbers 2018-0054/0073-66000, 2019-0035/0073-66000 and 2020-0095/073-66000). The following table presents the expenditures for the Citys federal award programs when there are multiple grant awards. See Table in Notes to the SEFA. The negative amount of $1,346,927 reported for ALN 14.218, Community Development Block Grants/Entitlement Grants program grant number B-20-MC-06-0542 represents correction of prior years federal expenditures. The City made an advance to a subrecipient in prior year, however the advance amount was returned by the subrecipient in the current fiscal year since they did not meet agreement terms. The negative amount of $230 reported for ALN 14.231, Emergency Solutions Grant Program grant number E- 19-MC-06-0542, represents correction of expenditures in prior year that moved to another funding source in the current fiscal year. The negative amounts of $778 reported for ALN 20.205, Highway Planning and Construction grant number HPLUL- 004(177), and $1,429 reported for ALN 20.600, State and Community Highway Safety grant number PT20154, represents expenditures incurred and reported in the Schedule in prior years that were ineligible and moved to another funding source in the current fiscal year.

Finding Details

Reference Number: 2022-001 Category of Finding: Other Compliance and Significant Deficiency Type of Finding: Significant Deficiency Federal program Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Agency: U.S. Department of the Treasury Pass Through Agency and Year: California State Water Resources Control Board (SWRCB) Pass-through Award Number and Year: CA3710020; FY 2021-22 Criteria: The California Water and Wastewater Arrearage Payment Program Guidelines: Water Arrearages, Section F: Water System Allocation to Customers, F.2.1. The water system must: Notify customers in writing of the amount credited. The acknowledgement must state that the credited amount is being provided through funding from the State Water Resources Control Board using federal American Rescue Plan Act (ARPA) funds. Title 2 ? Grants and Agreements, Subtitle A ? Office of Management and Budget Guidance for Grants and Agreements, Chapter II ? Office of Management and Budget Guidance, part 200 ? Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Wards, Subpart D ? Post Federal Award Requirements, ?200.303 Internal Controls. The 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 statute, 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 Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organization of the Treadway Commission (COSO). ?200.334 Retention requirements for records. Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure reports or, for Federal awards that are renewed quarterly or annually, form the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of subrecipient. Federal awarding agencies and pass-through entities must not impose any other record retention requirements upon non-Federal entities. The control objective related to documentation retention is to provide reasonable assurance that the Federal awards passed through the California SWRCB are used to credit the City?s water customer accounts, whose accounts had been in arrearages over 60 days, and the customer received a written notification of their arrearage being offset by the ARPA funds in accordance with the provision of California Water and Wastewater Arrearage Payment program Guidelines. Condition: During our audit of the Coronavirus State and Local Fiscal Recovery Funds program, we noted that the City?s Public Utilities Department (PUD) did not maintain documentation demonstrating compliance with Section F.2.1 of the grant guidelines with the State of California related to the Water and Wastewater Arrearage Payment Program. Of the 25 account credits selected for testing we were unable to validate that four (4) customers were sent the required notification in accordance with the program guidelines. Cause: The PUD did not implement a consistent process to maintain records demonstrating compliance with the requirement to notify customers of the nature and sources of the account credits funded by the Water and Wastewater Arrearage Payment Program. Effect: Not providing customer proper and timely information on relief programs could result in customers not knowing of needed government-funded support resulting in undue stress and/or incorrect payment expectations. There is also an expectation that customers are informed that the funding used to credit accounts was through the State Water Resources Control Board using federal American Rescue Plan Act (ARPA) funds. Questioned Costs: There are no questioned costs. Context: We selected 25 customer credits from a total population of 20,927, and noted that documentation of customer notification was not available for four (4) customer credits. Recommendation: The PUD should evaluate current practices of maintaining compliance documentation to ensure records are complete and consistent to support and demonstrate compliance with applicable requirements. Views of Responsible Officials and Planned Corrective Action: 1. Person responsible: Katie Keach, Deputy Director, Public Utilities Department 2. Corrective action plan: The Public Utilities Department has re-evaluated the procedures for maintaining compliance documentation. Changes will be implemented to the archiving process to ensure that all historical records of notifications are properly saved. Furthermore, internal controls will be enhanced to provide additional layers of approval prior to the completion of archiving. This will ensure all documentation will be readily available immediately after notifications are dispersed, and or in the future. 3. Implementation date: March 28, 2023
Reference Number: 2022-001 Category of Finding: Other Compliance and Significant Deficiency Type of Finding: Significant Deficiency Federal program Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Agency: U.S. Department of the Treasury Pass Through Agency and Year: California State Water Resources Control Board (SWRCB) Pass-through Award Number and Year: CA3710020; FY 2021-22 Criteria: The California Water and Wastewater Arrearage Payment Program Guidelines: Water Arrearages, Section F: Water System Allocation to Customers, F.2.1. The water system must: Notify customers in writing of the amount credited. The acknowledgement must state that the credited amount is being provided through funding from the State Water Resources Control Board using federal American Rescue Plan Act (ARPA) funds. Title 2 ? Grants and Agreements, Subtitle A ? Office of Management and Budget Guidance for Grants and Agreements, Chapter II ? Office of Management and Budget Guidance, part 200 ? Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Wards, Subpart D ? Post Federal Award Requirements, ?200.303 Internal Controls. The 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 statute, 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 Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organization of the Treadway Commission (COSO). ?200.334 Retention requirements for records. Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure reports or, for Federal awards that are renewed quarterly or annually, form the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of subrecipient. Federal awarding agencies and pass-through entities must not impose any other record retention requirements upon non-Federal entities. The control objective related to documentation retention is to provide reasonable assurance that the Federal awards passed through the California SWRCB are used to credit the City?s water customer accounts, whose accounts had been in arrearages over 60 days, and the customer received a written notification of their arrearage being offset by the ARPA funds in accordance with the provision of California Water and Wastewater Arrearage Payment program Guidelines. Condition: During our audit of the Coronavirus State and Local Fiscal Recovery Funds program, we noted that the City?s Public Utilities Department (PUD) did not maintain documentation demonstrating compliance with Section F.2.1 of the grant guidelines with the State of California related to the Water and Wastewater Arrearage Payment Program. Of the 25 account credits selected for testing we were unable to validate that four (4) customers were sent the required notification in accordance with the program guidelines. Cause: The PUD did not implement a consistent process to maintain records demonstrating compliance with the requirement to notify customers of the nature and sources of the account credits funded by the Water and Wastewater Arrearage Payment Program. Effect: Not providing customer proper and timely information on relief programs could result in customers not knowing of needed government-funded support resulting in undue stress and/or incorrect payment expectations. There is also an expectation that customers are informed that the funding used to credit accounts was through the State Water Resources Control Board using federal American Rescue Plan Act (ARPA) funds. Questioned Costs: There are no questioned costs. Context: We selected 25 customer credits from a total population of 20,927, and noted that documentation of customer notification was not available for four (4) customer credits. Recommendation: The PUD should evaluate current practices of maintaining compliance documentation to ensure records are complete and consistent to support and demonstrate compliance with applicable requirements. Views of Responsible Officials and Planned Corrective Action: 1. Person responsible: Katie Keach, Deputy Director, Public Utilities Department 2. Corrective action plan: The Public Utilities Department has re-evaluated the procedures for maintaining compliance documentation. Changes will be implemented to the archiving process to ensure that all historical records of notifications are properly saved. Furthermore, internal controls will be enhanced to provide additional layers of approval prior to the completion of archiving. This will ensure all documentation will be readily available immediately after notifications are dispersed, and or in the future. 3. Implementation date: March 28, 2023