Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirements: Other Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires non-federal entities receiving federal awards to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both the total federal expenditures and amounts passed through to subrecipients for the year. Per Title 2 CFR 200.502, the determination of when a Federal award must be expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition: SCRRA reported expenditures on the current year SEFA that were previously reported as expenditures on the prior year SEFA. Cause: SCRRA did not have adequate internal controls in place to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to the correction, the total federal expenditures on the SEFA was overstated by $3,098,000. Questioned Costs: None Context/Sampling: No sampling was used; program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year(s): No Recommendation: We recommend SCRRA enhance controls to ensure federal expenditures are accurately reported on the SEFA. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.
Program Name: Federal Transit Cluster CFDA No.: 20.500/20.507/20.525 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Program Name: Consolidated Rail Infrastructure and Safety Improvements Program CFDA No.: 20.325 Federal Grantor: U.S. Department of Transportation Award No. and Year: Various Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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 statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that SCRRA must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of SCRRA?s provisions for procurement requirements for the FTA program, we noted six (6) of the fourteen (14) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. During our testing of SCRRA?s provisions for procurement requirements for the CRISI program, we noted four (4) of the four (4) contracts selected for testing where there was no evidence that SCRRA verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with SCRRA?s policy. Cause: SCRRA did not adhere to established policies and procedures to verify the information described in the condition prior to entering the transactions. Effect: SCRRA?s control was not consistently applied, which required verification of suspension or debarment prior to entering the contract. However, the verification of suspension and debarment was subsequently performed and documented by SCRRA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy-two (72) procurement contracts were selected for procurement and suspension and debarment testing for the FTA program. A nonstatistical sample of four (4) out of (4) procurement contracts were selected for procurement and suspension and debarment testing for the CRISI program. Repeat Finding from Prior Year(s): Yes Southern California Regional Rail Authority Schedule of Findings and Questioned Costs Year Ended June 30, 2022 Recommendation: We recommend SCRRA adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management Agrees. See separate corrective action plan.