Equipment Management (Significant Deficiency/Compliance) ALN No. 14.218 – Community Development Block Grant Criteria: The Uniform Guidance requires non-federal entities to maintain effective internal control and accountability over equipment acquired with federal funds. Specifically, 2 CFR 200.313(d)(2) requires a physical inventory of equipment to be conducted and reconciled with property records at least once every two years. These requirements apply to equipment purchased with CDBG funds. Condition: We noted that the City did not perform a physical inventory of equipment purchased with federal funds. As a result, the City was unable to provide documentation demonstrating that a biennial physical inventory had been conducted and reconciled to its property records. Effect: The lack of a physical inventory conducted on equipment acquired with federal funds results in noncompliance with 2 CFR 200.313(d)(2). Cause: The City did not have adequate procedures in place to ensure compliance with federal equipment management requirements, including the timely performance and documentation of physical inventories. Questioned Costs: $0 Recommendation: We recommend the City establish and implement formal equipment management procedures to ensure that a physical inventory of all federally funded equipment is performed and documented at least once every two years. The inventory should be reconciled to the City’s equipment records, discrepancies should be investigated and resolved timely, and supporting documentation should be retained to demonstrate compliance with Uniform Guidance requirements. Repeat Finding from Prior Year(s): N/A Views of Responsible Officials: See management’s corrective action plan.
Reporting (Significant Deficiency/Compliance) ALN No. 14.218 – Community Development Block Grants/Entitlement Grants Criteria: The Community Development Block Grant (CDBG) program requires grantees to complete the IDIS Cash on Hand Quarterly Report and submit it to the applicable HUD field office through IDIS on a quarterly basis. The quarterly Cash on Hand report must be submitted within 30 days after the end of the reporting period. For Quarter 1, covering October 1 through December 31, the report is due January 30. Condition: During our testing of reporting requirements within the City’s Community Development Block Grant (CDBG) program, we selected a sample of four reports and noted one exception. Specifically, the City did not timely submit the required PR-29 Cash on Hand report for the first quarter. The report was due January 30, 2025; however, it was not submitted until February 14, 2025. Effect: Failure to submit the PR-29 Cash on Hand report by the required deadline results in noncompliance with federal reporting requirements and may limit HUD’s ability to timely monitor the City’s cash on hand and related CDBG grant activity. Cause: The City did not have adequate procedures in place to ensure personnel responsible for CDBG reporting were aware of applicable reporting deadlines or that required reports were monitored to ensure timely submission. Questioned Costs: $0 Recommendation: We recommend the City implement and enforce procedures to ensure all required CDBG reports are prepared, reviewed, and submitted by established deadlines to maintain compliance with program requirements. These procedures should include assigning responsibility, maintaining a reporting calendar with reminders, and implementing a secondary review to verify submission before the deadline. Repeat Finding from Prior Year(s): N/A Views of Responsible Officials: See management’s corrective action plan.
Rehabilitation (Significant Deficiency) ALN No. 14.218 – Community Development Block Grants/Entitlement Grants Criteria: The Uniform Guidance requires recipients to establish, document, and maintain effective internal control over federal awards that provides reasonable assurance that the award is managed in compliance with federal statutes, regulations, and the terms and conditions of the award. Effective internal controls over CDBG rehabilitation activities should include documented review and approval of pre-rehabilitation inspection documentation by the designated approving authority and appropriate segregation of duties between preparation and approval functions. Condition: During testing of internal controls over compliance for CDBG rehabilitation activities, we selected a sample of three rehabilitation projects and noted that pre-rehabilitation inspection documentation was not consistently approved by the appropriate level of authority. Specifically, housing staff signed both the preparer and CDBG Director approval sections based on instruction from management. Effect: When the same individual signs both the preparer and approval sections, the effectiveness of segregation of duties and of review controls are weakened. This increases the risk that errors, omissions, or noncompliance related to rehabilitation activities may not be prevented or detected and corrected timely. Cause: The City did not have adequate procedures in place to ensure that inspection approvals were performed and documented by the designated approving authority. Additionally, management’s instructions allowed housing staff to sign both the preparer and approval sections, which weakened segregation of duties. Questioned Costs: $0 Recommendation: We recommend that the City implement procedures to ensure that inspection approvals are performed and documented by the designated approving authority to strengthen internal controls and maintain appropriate oversight of rehabilitation activities. The procedures should clearly assign preparer and reviewer responsibilities, prohibit the same individual from signing both sections unless formally approved as an exception, and require evidence of review to be retained in the project file. Repeat Finding from Prior Year(s): N/A Views of Responsible Officials: See management’s corrective action plan.
Section 3 Policy (Significant Deficiency) ALN No. 14.218 – Community Development Block Grants/Entitlement Grants Criteria: The CDBG program is subject to Section 3 requirements under 24 CFR Part 75 for applicable Section 3 projects. Effective internal controls should include written policies and procedures that identify when Section 3 applies, define responsible personnel, describe required worker certifications and supporting documentation, and establish monitoring and retention requirements. Condition: During testing of internal controls over compliance for the City’s CDBG program, we noted the City did not have an established set of policies and procedures related to Section 3 workers. As a result, the City did not have formal procedures to ensure documentation was established and maintained to demonstrate that workers on applicable Section 3 projects met the definition of a Section 3 worker or Targeted Section 3 worker at the time of hire or the f irst reporting period. Effect: Without established Section 3 policies and procedures, the City may not consistently identify applicable Section 3 projects, obtain required worker certifications, retain sufficient supporting documentation, or monitor compliance with Section 3 requirements. This increases the risk of noncompliance with CDBG program requirements. Cause: The City did not have adequate procedures in place to ensure Section 3 requirements were f ormally incorporated into its CDBG program administration process. Questioned Costs: $0 Recommendation: We recommend the City implement Section 3 policies and procedures to ensure compliance with applicable requirements. These procedures should identify applicable Section 3 projects, assign responsibility for compliance monitoring, require worker certifications and supporting documentation to be obtained at the time of hire or the first reporting period, establish documentation retention requirements, and include a review process to verify that required documentation is complete and retained. Repeat Finding from Prior Year(s): N/A Views of Responsible Officials: See management’s corrective action plan.
Allowable Costs/Activities Allowed (Significant Deficiency) ALN No. 14.218 - Community Development Block Grants/Entitlement Grants Criteria: The Uniform Guidance requires non-federal entities to maintain effective internal controls over federal awards that provide reasonable assurance that federal programs are administered in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Costs charged to federal awards must be necessary, reasonable, allocable, adequately documented, and consistent with the applicable cost principles and program requirements. Effective controls over allowable costs and activities include documented authorization and approval of expenditures before costs are incurred, including issuance and approval of purchase orders or equivalent documentation when required by the City's policies and procedures. Condition: During our testing of expenditures for allowable costs and activities allowed within the City's Community Development Block Grant (CDBG) program, we selected a sample of 17 expenditures and noted that, for 15 of the 17 selections tested, the City did not consistently maintain documentation demonstrating that purchase orders were issued and approved before expenditures were incurred. Specifically, purchase orders were not consistently issued and approved prior to invoice dates, indicating that authorization of certain CDBG expenditures was not documented prior to incurring costs. Effect: Without documented purchase order approval prior to incurring costs, the City may not be able to demonstrate that federal expenditures were properly authorized, allowable, and consistent with applicable program requirements. This increases the risk that unallowable or unsupported costs could be charged to federal awards and may result in questioned costs or noncompliance with federal award requirements. Cause: The City did not have adequate procedures in place to ensure purchase orders for federally funded expenditures were prepared, approved, and retained prior to incurring costs. Procedures for maintaining documentation supporting authorization of federal expenditures were not consistently followed. Questioned Costs: $0 Recommendation: We recommend the City implement and enforce procedures requiring purchase orders or equivalent authorization documentation to be prepared and approved prior to incurring federally funded expenditures. Evidence of approval should be retained in the grant expenditure file, and after-the-fact documentation should be limited to exceptional circumstances with documented supervisory approval. We further recommend the City implement a review process to verify that purchase order documentation is complete before expenditures are charged to federal awards. Repeat Finding from Prior Year(s): N/A Views of Responsible Officials: See management's corrective action plan.
Reporting (Significant Deficiency/Compliance) ALN No. 16.922 – Equitable Sharing Program Criteria: The Equitable Sharing Program requires participating agencies to submit the Equitable Sharing Agreement and Certification (ESAC) report no later than November 30 following the end of the program year. Timely submission is necessary to demonstrate compliance with program requirements. Condition: This finding is carried forward from the prior year. While this program was not a major program audited in 2025, management indicated that the status of the corrective action for this finding is in progress. We noted the City did not submit its ESAC report by the required deadline. Effect: Failure to submit the ESAC by the required deadline results in noncompliance with federal reporting requirements and may affect the City’s standing and continued eligibility in the Equitable Sharing Program. Cause: The City did not have adequate procedures in place to ensure that personnel responsible for program administration were aware of the ESAC reporting deadline or that the submission was monitored to ensure timely filing. Questioned Costs: $0 Recommendation: We recommend the City implement procedures to ensure personnel are aware of program reporting deadlines and that required reports, such as the ESAC, are submitted timely. This should include assigning responsibility, establishing a reporting calendar with reminders, and implementing a secondary review to verify submission before the deadline. Repeat Finding from Prior Year(s): 2024-018 Views of Responsible Officials: See management’s corrective action plan.
Equipment Management (Significant Deficiency/Compliance) ALN No. 16.922 - Equitable Sharing Program Criteria: The Equitable Sharing Guide requires participating agencies to maintain complete and accurate inventory records for all assets purchased with Equitable Sharing Program funds. The Guide specifies that all assets, not only high-dollar items, must be inventoried, and that records must include item-level detail sufficient to track each piece of equipment individually. Effective internal controls further require that inventory listings be accurate, complete, and periodically reviewed to ensure proper stewardship of program-funded assets. Condition: During our review of the City's inventory records for the Equitable Sharing Program, we noted multiple errors and omissions within the equipment tracking spreadsheet maintained by the City. Specifically: - Costs for multiple assets purchased together were combined into a single total preventing the City from tracking each asset on an item-by-item basis. - The listing did not reflect all program related equipment, resulting in incomplete inventory records. - The listing contained data entry errors, including incorrectly placed decimals that overstated the value of certain assets. - The City inventoried only larger items rather than all assets required to be tracked under the Equitable Sharing Guide. These issues were brought to the attention of City personnel and were subsequently corrected during the audit Effect: Incomplete or inaccurate inventory records increase the risk that program-funded assets may be misstated, lost, misused, or not properly safeguarded. Inaccurate data may also impair the City's ability to demonstrate compliance with federal asset management requirements and may result in questioned costs. Cause: Internal controls over equipment tracking and inventory management were not adequately designed or implemented. The City did not maintain item-level detail for all assets purchased with Equitable Sharing funds and lacked a formal review process to ensure the accuracy and completeness of its inventory records. Questioned Costs: $0 Recommendation: We recommend the City maintain a detailed, item by item inventory records for all assets purchased with Equitable Sharing Program funds, including descriptions, quantities, unit costs serial numbers (if applicable), and acquisition dates. We also recommend a periodic management review to verify that inventory records are accurate, complete, and properly valued. Repeat Finding from Prior Year(s): 2024-019 Views of Responsible Officials: See management's corrective action plan.
Procurement, Suspension and Debarment (Significant Deficiency/Compliance) ALN No. 15.916 – Outdoor Recreation Acquisition, Development and Planning ALN No. 16.922 – Equitable Sharing Program ALN No. 20.205 – Highway Planning and Construction Criteria: The federal awards suspension and debarment compliance requirements prohibit non-federal entities from contracting or making subawards to parties that are suspended, debarred, or otherwise excluded from participating in federally funded programs. Compliance with this requirement may be documented through one of the following: - A sam.gov verification printout; - A written certification from the vendor; or - A clause in the contract requiring the vendor to affirm it is not suspended or debarred. This must be performed prior to entering into covered transactions, including procurements of goods and services equal to or exceeding $25,000. Condition: This finding is carried forward from the prior year. For transactions subject to suspension and debarment requirements, we noted the City did not consistently document verification that vendors had not been suspended, debarred or otherwise excluded from federal contracting eligibility. Specifically, we noted no evidence that a sam.gov exclusions check was conducted, that written vendor certification was obtained, or that the contract documents included the required suspension and debarment clauses. As a result, the City could not demonstrate compliance with suspension and debarment requirements. Effect: Failure to verify and document suspension and debarment status increases the risk that federal funds could be expended with vendors who are suspended or debarred from participating in federally funded programs. Cause: The City did not have adequate internal controls in place to ensure suspension and debarment verification was performed and documented for all federally funded procurements. Questioned Costs: $0 Recommendation: We recommend the City strengthen internal controls over procurement and vendor eligibility by implementing a formal procedure requiring staff to verify suspension and debarment status before entering into any covered transaction equal to or greater than $25,000. This verification should be conducted before entering into the transactions and evidence of such review should be retained to support compliance with the requirement. Repeat Finding from Prior Year(s): 2024-016 Views of Responsible Officials: See management’s corrective action plan.
Cash Management and Reporting (Significant Deficiency) ALN No. 15.916 – Outdoor Recreation Acquisition, Development and Planning Criteria: Effective internal controls over cash management and reporting include a review and approval of reimbursement requests before they are submitted. This review and approval are important to ensure reports being submitted are accurate, include only costs that are allowable and eligible for reimbursement. The review and approval should be documented and retained as evidence the internal control occurred and being followed. Condition: This finding is carried forward from the prior year. While this program was not a major program audited in 2025, management indicated that the status of the corrective action for this finding is in progress. The City did not have documented evidence to show that reports submitted for reimbursement were reviewed and approved before they were submitted. As a result, we were unable to verify whether the control was in place or was followed. Effect: The lack of a review and approval may result in errors on reports submitted. Cause: The City did not have a formal process in place to ensure reimbursement requests are reviewed and approved prior to being submitted. Questioned Costs: $0 Recommendation: We recommend the City strengthen internal controls by implementing a process where all reports, including reimbursement requests, are reviewed and approved and that evidence of such review be documented with a signature and date and retained as part of the City’s records. Repeat Finding from Prior Year(s): 2024-017 Views of Responsible Officials: See management’s corrective action plan.