Audit 406093

United States Environmental Protection Agency – 66.958 – Water Infrastructure Finance and Innovation Act (WIFIA) Agreement No(s): WIFIA – N19137LA Criteria: Under 2 CFR § 200.403, costs charged to a federal award must be necessary, reasonable, and allocable to the federal award and must conform to any limitations or exclusions set forth in the terms and conditions of the award. The WIFIA loan agreement further limits eligible costs to those incurred for EPA-approved projects. Condition: During testing of WIFIA loan draws for the year ended December 31, 2025, we noted that $3,167,614 million of project costs were funded through WIFIA loan draws for a project that had not yet received approval from the EPA at the time the costs were incurred and drawn. Context/Population: The exception was identified during testing of WIFIA loan draws, which totaled $93,409,714 million for the year ended December 31, 2025. The questioned costs totaling $3,167,614 relate to one project that had not yet received EPA approval at the time of the draw. Cause: The Board’s processes for reviewing and approving project eligibility prior to requesting WIFIA loan draws did not include sufficient controls to ensure that projects had received formal EPA approval in accordance with the WIFIA loan agreement before costs were submitted for reimbursement. Effect: As a result, federal funds were used to finance costs that were not associated with an EPA-approved project at the time of draw, resulting in questioned costs of $3,167,614. This represents noncompliance with federal requirements and the terms and conditions of the WIFIA loan agreement and could result in potential disallowance or repayment to the federal agency. Identification of a repeat finding: This is not a repeat finding. Recommendation: We recommend that the Board strengthen its controls over WIFIA draw requests to ensure that: • All projects included in a draw request have received formal EPA approval in accordance with the loan agreement; • A documented review process is performed prior to submission of each draw request to confirm project eligibility; and • A timely reconciliation or crosswalk is maintained linking project costs to approved WIFIA project designations. View of Responsible Officials: Management acknowledges the finding relative to formal documentation for eligible project costs and will enhance review procedures for monthly WIFIA loans draws to have written contemporaneous evidence from the lender in addition to preliminary approval received for project transfers or changes (i.e. renaming of subprojects listed in the loan closing documents within the same scope approved in the loan). The project changes materialized due to a change in expected timing of Sewer Utility work included in joint projects with the City’s Department of Public Works. As a result, standalone projects were executed to complete the required work by the October 2025 deadline mandated in the Sewer Consent Decree. The changes were discussed with the lender upon notification from the Department of Public Works and included in WIFIA quarterly reporting while the formal project approvals are in process. The Utility’s Project Delivery Unit Director is responsible for ensuring that this corrective action is accomplished with an estimated timeline for completion by September 30, 2026. The WIFIA project scope is defined as: I. Water Line Replacement via the Joint Infrastructure (JIRR) Program; II. Sewer Line Replacement via the Joint Infrastructure Recovery Roads (JIRR) Program; III. Sewer System Evaluation and Rehabilitation Program (SSERP); and IV. Sewer Force Main Replacement and Improvement. The eligible activities include, restoration and replacement of damaged gravity sanitary sewer mains, manhole rehabilitation and repair, CIPP lining and point repairs, Water line replacement and repair, Roadway restoration and ADA curb ramp improvements associated with the utility work.