Federal Agency: United States Department of Housing and Urban Development Federal Program Name: CDBG Entitlement Grants Cluster: Community Development Block Grant (CDBG) Assistance Listing Number: 14.218 Federal Award Identification Number and Year: B-21-MC-06-0593; B-20-MC-06-0593; B-19-MC-06-0593; B-18-MC-06-0593; B-17-MC-06-0593; B-16-MC-06-0593; Award Years 2021, 2020, 2019, 2018, 2017, and 2016 Award Period: Fiscal Year 2021-2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance (Allowable Costs) ? Other Matter (Allowable Costs) Criteria or Specific Requirement: 2 CFR Part 200, section 200.303 of the Uniform states that a 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. Condition: The City has specific CDBG grant personnel that are responsible for reviewing all grant expenditures to ensure they are allowable. However, the designated grant personnel are reviewing the expenditures after the disbursement has been made instead of prior to authorizing the disbursement and charging to the grant. In addition, there is no formal documentation retained to illustrate that all disbursements were reviewed. Internal controls over federal awards should include authorization by appropriate grant personnel prior to such disbursements occurring. Questioned Costs: None noted. Context: All disbursements are reviewed in the same manner. Cause: The City will correct any unallowed expenditures identified by grant personnel by moving such expenditures to an appropriate fund and revenue source. These procedures were deemed by the City to be adequate. Effect: Without formal documentation of the review process, the review might not occur without management's knowledge. In addition, internal controls should have a preventative as well as detective aspect to ensure timely identification of any unallowable costs or activities. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the City either utilize the electronic authorization capabilities of the accounting system or manually initial or sign invoices to have approvals of all grants expenditures by the designated grant personnel prior to disbursing the funds.
Federal Agency: United States Department of Housing and Urban Development Federal Program Name: CDBG Entitlement Grants Cluster: Community Development Block Grant (CDBG) Assistance Listing Number: 14.218 Federal Award Identification Number and Year: B-21-MC-06-0593; B-20-MC-06-0593; B-19-MC-06-0593; B-18-MC-06-0593; B-17-MC-06-0593; B-16-MC-06-0593; Award Years 2021, 2020, 2019, 2018, 2017, and 2016 Award Period: Fiscal Year 2021-2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance (Allowable Costs) ? Other Matter (Allowable Costs) Criteria or Specific Requirement: Allowable Costs: Uniform Guidance Title 2, Subtitle A, Chapter II, Part 200, Subpart E, ?200.430 allows for budget estimates for personal services to be used for interim accounting purposes provided, among other criteria, that ?The nonfederal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. All necessary adjustments must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.? Allowable Costs: Uniform Guidance Title 2, Subtitle A, Chapter II, Part 200, Subpart E, ?200.430 requires payroll records to support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: From July 2021 through September 2021, personal services charged were recorded for two employees based on budget to the program and an after-the-fact determination of personal services charged to the program was not conducted and adjustments, if necessary, were not recorded. In addition, The City corrected this matter beginning October 2021 and this finding did not apply from October 2021 through June 2022. In addition, in some cases, overtime charges occurred that were not supported by timesheets. Questioned Costs: The amount of known salaries and fringe benefits charged to the federal program that were based on budgeted percentages during the fiscal year 2021-2022 is $24,358. The amount of overtime charged to the federal program that was not supported by timesheets was $853. The likely amount of questioned costs for overtime charges cannot be determined since there are no records that accurately reflect the actual work performed. Context: Payroll and fringe benefits were charged based on budgeted percentages in 2 of 12 samples tested. There was a total of 4 pay periods where two employees' wages and fringe benefits were charged to the program based on budgeted percentages. Overtime was charged without a supporting timesheet in 2 out of 12 samples tested. Cause: The City received the comment in prior years and did not make changes for all employees for the fiscal year 2021-2022. Overtime charges that occurred without a timesheet was an error not identified or corrected through the internal control process. Effect: The amount of personal services charged to the federal award may be over or understated. Repeat Finding: Repeat of prior year finding number 2021-006. Recommendation: We recommend that personnel track their actual time spent working on the program (including all other hours worked) so that an after-the-fact adjustments can be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated. This recommendation was implemented by the City beginning October 2021. We recommend that the City implement policies and procedures to review all charges to federal awards, including overtime, to verify amounts are supported by timesheets that are approved by appropriate supervisors.
Federal Program Name: CDBG Entitlement Grants Cluster: Community Development Block Grant (CDBG). Assistance Listing Number: 14.218. Federal Award Identification Number and Year: B-21-MC-06-0593; B-20-MC-06-0593; B-19-MC-06-0593; B-18-MC-06-0593; B-17-MC-06-0593; B-16-MC-06-0593; Award Years 2021, 2020, 2019, 2018, 2017, and 2016 Award Period: Fiscal Year 2021-2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance (Allowable Costs) ? Other Matter (Allowable Costs) Criteria or Specific Requirement: Allowable Costs: Uniform Guidance Title 2, Subtitle A, Chapter II, Part 200, Subpart E, ?200.430 requires payroll charges to be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: After the findings the City received in the prior year audit, the City revised the internal controls over payroll to require a supervisor's review and approval of hours charged to federal awards on the electronic timesheets, which is in line with the requirements of the Uniform Guidance. In 2 out of 12 payroll transactions tested, there was no supervisor approval of hours charged to the federal award, which was a lack of internal controls. Questioned Costs: None since hours worked were documented (except as noted in finding 2022-005), but the support for the supervisor approval was not able to be inspected and verified. Context: The payroll charges without supervisor approval totals $5,188 and occurred in 2 out of 12 transactions tested. Cause: Upon receiving the prior year finding, the City was not able to implement the payroll internal control changes for all transactions in the next fiscal year since part of the year had passed before the audit procedures could be performed. Effect: The payroll records are not in compliance with the requirements of the Uniform Guidance. Repeat Finding: Repeat of prior year finding number 2021-007. Recommendation: We recommend that the City ensure all timesheets require approval of hours charged to federal awards by a supervisor so that the City is in compliance with the Uniform Guidance payroll documentation requirements.
Federal Program Name: CDBG Entitlement Grants Cluster: Community Development Block Grant (CDBG) Assistance Listing Number: 14.218 Federal Award Identification Number and Year: B-21-MC-06-0593; B-20-MC-06-0593; B-19-MC-06-0593; B-18-MC-06-0593; B-17-MC-06-0593; B-16-MC-06-0593; Award Years 2021, 2020, 2019, 2018, 2017, and 2016 Award Period: Fiscal Year 2021-2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance (Reporting) ? Other Matter (Reporting) Criteria or Specific Requirement: Reporting: Prime recipients awarded a federal grant greater than or equal to $30,000 are subject to FFATA sub-award reporting requirements as outlined in the Office of Management and Budgets guidance issued August 13, 2020. The prime recipient is required to file a FFATA subaward report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. Condition: The City is a prime recipient and provided subawards totaling $135,000 to three recipients, each over the $30,000 reporting threshold. Three out of the three FFATA reports were filed for these recipients, but all were filed after the end of the month following the month in which the sub-grant was awarded. Questioned Costs: None noted. Context: The City is a prime recipient and provided subawards totaling $135,000 to three recipients, each over the $30,000 reporting threshold. Three out of the three FFATA reports were filed for these recipients, but all were filed after the end of the month following the month in which the sub-grant was awarded. Cause: The City was not aware of the FFATA reporting requirements. Effect: The City is not in compliance with the FFATA reporting requirements. Repeat Finding: Repeat of prior year finding number 2021-008. Recommendation: We recommend the City implement policies and procedures to ensure that FFATA reporting occurs for all subawards of $30,000 or more for all federal awards and that the reporting be performed timely.
Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: None Award Period: Fiscal Year 2021-2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance (Suspension and Debarment) ? Other Matter (Suspension and Debarment) Criteria or Specific Requirement: Suspension and Debarment: 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of suspension and debarment. The City should have internal controls designed to ensure compliance with those provisions. Condition: The City was not able to provide supporting documentation that the verification of suspension or debarment was performed prior to entering into the contract. Questioned Costs: None noted. Context: There were only two vendors during fiscal year 2021-2022 that were a covered transaction for this program. While the City did not perform the suspension and debarment verification for these vendors tested, the vendors were not on the suspended and debarred listing. Cause: The City did not maintain supporting documentation that the verification of suspension or debarment was performed prior to entering into the contract. The vendors are routinely used for IT procurement and the City has ongoing contracts. The City was under the impression that a separate verification of this vendor was not necessary. Effect: No vendors were noted that were suspended or debarred; however, there was no documentation retained to verify that the City followed their internal controls to ensure the vendor was not suspended or debarred prior to entering into the transactions. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the City implement procedures to ensure that verification documentation for suspension and debarment is maintained to support the City's internal control over compliance.
Federal Agency: United States Department of Housing and Urban Development Federal Program Name: CDBG Entitlement Grants Cluster: Community Development Block Grant (CDBG) Assistance Listing Number: 14.218 Federal Award Identification Number and Year: B-21-MC-06-0593; B-20-MC-06-0593; B-19-MC-06-0593; B-18-MC-06-0593; B-17-MC-06-0593; B-16-MC-06-0593; Award Years 2021, 2020, 2019, 2018, 2017, and 2016 Award Period: Fiscal Year 2021-2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance (Allowable Costs) ? Other Matter (Allowable Costs) Criteria or Specific Requirement: 2 CFR Part 200, section 200.303 of the Uniform states that a 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. Condition: The City has specific CDBG grant personnel that are responsible for reviewing all grant expenditures to ensure they are allowable. However, the designated grant personnel are reviewing the expenditures after the disbursement has been made instead of prior to authorizing the disbursement and charging to the grant. In addition, there is no formal documentation retained to illustrate that all disbursements were reviewed. Internal controls over federal awards should include authorization by appropriate grant personnel prior to such disbursements occurring. Questioned Costs: None noted. Context: All disbursements are reviewed in the same manner. Cause: The City will correct any unallowed expenditures identified by grant personnel by moving such expenditures to an appropriate fund and revenue source. These procedures were deemed by the City to be adequate. Effect: Without formal documentation of the review process, the review might not occur without management's knowledge. In addition, internal controls should have a preventative as well as detective aspect to ensure timely identification of any unallowable costs or activities. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the City either utilize the electronic authorization capabilities of the accounting system or manually initial or sign invoices to have approvals of all grants expenditures by the designated grant personnel prior to disbursing the funds.
Federal Agency: United States Department of Housing and Urban Development Federal Program Name: CDBG Entitlement Grants Cluster: Community Development Block Grant (CDBG) Assistance Listing Number: 14.218 Federal Award Identification Number and Year: B-21-MC-06-0593; B-20-MC-06-0593; B-19-MC-06-0593; B-18-MC-06-0593; B-17-MC-06-0593; B-16-MC-06-0593; Award Years 2021, 2020, 2019, 2018, 2017, and 2016 Award Period: Fiscal Year 2021-2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance (Allowable Costs) ? Other Matter (Allowable Costs) Criteria or Specific Requirement: Allowable Costs: Uniform Guidance Title 2, Subtitle A, Chapter II, Part 200, Subpart E, ?200.430 allows for budget estimates for personal services to be used for interim accounting purposes provided, among other criteria, that ?The nonfederal entity?s system of internal controls includes processes to review after-the-fact interim charges made to a federal awards based on budget estimates. All necessary adjustments must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated.? Allowable Costs: Uniform Guidance Title 2, Subtitle A, Chapter II, Part 200, Subpart E, ?200.430 requires payroll records to support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: From July 2021 through September 2021, personal services charged were recorded for two employees based on budget to the program and an after-the-fact determination of personal services charged to the program was not conducted and adjustments, if necessary, were not recorded. In addition, The City corrected this matter beginning October 2021 and this finding did not apply from October 2021 through June 2022. In addition, in some cases, overtime charges occurred that were not supported by timesheets. Questioned Costs: The amount of known salaries and fringe benefits charged to the federal program that were based on budgeted percentages during the fiscal year 2021-2022 is $24,358. The amount of overtime charged to the federal program that was not supported by timesheets was $853. The likely amount of questioned costs for overtime charges cannot be determined since there are no records that accurately reflect the actual work performed. Context: Payroll and fringe benefits were charged based on budgeted percentages in 2 of 12 samples tested. There was a total of 4 pay periods where two employees' wages and fringe benefits were charged to the program based on budgeted percentages. Overtime was charged without a supporting timesheet in 2 out of 12 samples tested. Cause: The City received the comment in prior years and did not make changes for all employees for the fiscal year 2021-2022. Overtime charges that occurred without a timesheet was an error not identified or corrected through the internal control process. Effect: The amount of personal services charged to the federal award may be over or understated. Repeat Finding: Repeat of prior year finding number 2021-006. Recommendation: We recommend that personnel track their actual time spent working on the program (including all other hours worked) so that an after-the-fact adjustments can be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated. This recommendation was implemented by the City beginning October 2021. We recommend that the City implement policies and procedures to review all charges to federal awards, including overtime, to verify amounts are supported by timesheets that are approved by appropriate supervisors.
Federal Program Name: CDBG Entitlement Grants Cluster: Community Development Block Grant (CDBG). Assistance Listing Number: 14.218. Federal Award Identification Number and Year: B-21-MC-06-0593; B-20-MC-06-0593; B-19-MC-06-0593; B-18-MC-06-0593; B-17-MC-06-0593; B-16-MC-06-0593; Award Years 2021, 2020, 2019, 2018, 2017, and 2016 Award Period: Fiscal Year 2021-2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance (Allowable Costs) ? Other Matter (Allowable Costs) Criteria or Specific Requirement: Allowable Costs: Uniform Guidance Title 2, Subtitle A, Chapter II, Part 200, Subpart E, ?200.430 requires payroll charges to be supported by a system of internal control, which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: After the findings the City received in the prior year audit, the City revised the internal controls over payroll to require a supervisor's review and approval of hours charged to federal awards on the electronic timesheets, which is in line with the requirements of the Uniform Guidance. In 2 out of 12 payroll transactions tested, there was no supervisor approval of hours charged to the federal award, which was a lack of internal controls. Questioned Costs: None since hours worked were documented (except as noted in finding 2022-005), but the support for the supervisor approval was not able to be inspected and verified. Context: The payroll charges without supervisor approval totals $5,188 and occurred in 2 out of 12 transactions tested. Cause: Upon receiving the prior year finding, the City was not able to implement the payroll internal control changes for all transactions in the next fiscal year since part of the year had passed before the audit procedures could be performed. Effect: The payroll records are not in compliance with the requirements of the Uniform Guidance. Repeat Finding: Repeat of prior year finding number 2021-007. Recommendation: We recommend that the City ensure all timesheets require approval of hours charged to federal awards by a supervisor so that the City is in compliance with the Uniform Guidance payroll documentation requirements.
Federal Program Name: CDBG Entitlement Grants Cluster: Community Development Block Grant (CDBG) Assistance Listing Number: 14.218 Federal Award Identification Number and Year: B-21-MC-06-0593; B-20-MC-06-0593; B-19-MC-06-0593; B-18-MC-06-0593; B-17-MC-06-0593; B-16-MC-06-0593; Award Years 2021, 2020, 2019, 2018, 2017, and 2016 Award Period: Fiscal Year 2021-2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance (Reporting) ? Other Matter (Reporting) Criteria or Specific Requirement: Reporting: Prime recipients awarded a federal grant greater than or equal to $30,000 are subject to FFATA sub-award reporting requirements as outlined in the Office of Management and Budgets guidance issued August 13, 2020. The prime recipient is required to file a FFATA subaward report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. Condition: The City is a prime recipient and provided subawards totaling $135,000 to three recipients, each over the $30,000 reporting threshold. Three out of the three FFATA reports were filed for these recipients, but all were filed after the end of the month following the month in which the sub-grant was awarded. Questioned Costs: None noted. Context: The City is a prime recipient and provided subawards totaling $135,000 to three recipients, each over the $30,000 reporting threshold. Three out of the three FFATA reports were filed for these recipients, but all were filed after the end of the month following the month in which the sub-grant was awarded. Cause: The City was not aware of the FFATA reporting requirements. Effect: The City is not in compliance with the FFATA reporting requirements. Repeat Finding: Repeat of prior year finding number 2021-008. Recommendation: We recommend the City implement policies and procedures to ensure that FFATA reporting occurs for all subawards of $30,000 or more for all federal awards and that the reporting be performed timely.
Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: None Award Period: Fiscal Year 2021-2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance (Suspension and Debarment) ? Other Matter (Suspension and Debarment) Criteria or Specific Requirement: Suspension and Debarment: 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of suspension and debarment. The City should have internal controls designed to ensure compliance with those provisions. Condition: The City was not able to provide supporting documentation that the verification of suspension or debarment was performed prior to entering into the contract. Questioned Costs: None noted. Context: There were only two vendors during fiscal year 2021-2022 that were a covered transaction for this program. While the City did not perform the suspension and debarment verification for these vendors tested, the vendors were not on the suspended and debarred listing. Cause: The City did not maintain supporting documentation that the verification of suspension or debarment was performed prior to entering into the contract. The vendors are routinely used for IT procurement and the City has ongoing contracts. The City was under the impression that a separate verification of this vendor was not necessary. Effect: No vendors were noted that were suspended or debarred; however, there was no documentation retained to verify that the City followed their internal controls to ensure the vendor was not suspended or debarred prior to entering into the transactions. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the City implement procedures to ensure that verification documentation for suspension and debarment is maintained to support the City's internal control over compliance.