Information of the Federal Programs: Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grants / Entitlement Grants Federal Agency: Department of Housing and Urban Development Federal Award Number and Award Year: B-20-MC-06-0559, B-20-MW-06-0559, and B-21-MC-06-0559 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to the Guidance on Consolidated Annual Performance and Evaluation Report (?CAPER?) (24 CFR 91.520). Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Section IV.B.2.(c) of the CDBG-CV Notice reiterated the waiver authorized by a May 7, 2020, HUD memorandum (found in the waiver information link noted in IV. Other Information, below) that waives the 90 day requirement for program year 2019 annual performance and evaluation reports, subject to the condition that within 180 days after the evaluation reports, subject to the condition that within 180 days after the close of a jurisdiction?s program year that it submit its performance report. Auditors are only expected to test information extracted from IDIS in the following system-generated reports and which include (1) PR26 ? CDBG Financial Summary Report (?PR26?). A grantee?s CAPER, submitted through the IDIS e-Con Planning Suite, is due 90 days after the close of a jurisdiction?s program year. Pursuant to Guidance on Section 15011 of the CARES Act requires that recipients of $150,000 or more of CARES Act funding submit, not later than 10 days after the end of each calendar quarter, a report containing: information regarding the amount of funds received; the amount of funds obligated or expended for each project or activity; a detailed list of all such projects or activities, including a description of the project or activity; and detailed information on any subcontracts or subgrants awarded by the recipient. This report is limited to CDBG-CV funding and does not include other CDBG funds that may be used to address coronavirus. Grantees and subrecipients have reported data meeting the Section 15011 requirements at usaspending.gov. The Pandemic Response Accountability Committee (PRAC), an independent oversight committee within the Council of the Inspectors General on Integrity and Efficiency, has determined that the data reported in usaspending.gov has fulfilled these reporting requests. (?Section 15011 Report?). Condition: The City did not submit the CAPER on time. The CAPER was submitted on November 28, 2022. In addition, the City did not submit Section 15011 report for the year ended June 30, 2022. Cause: The City staff was unavailable prior to the due date of September 30, 2022 to ensure filing CAPER timely. In addition, the City was not aware of the Section 15011 reporting requirement. Effect or Potential Effect: Delay in filing and not filing the reports resulted in noncompliance with the compliance requirements. Questioned Costs: None. Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: Repeated finding as 2021-001. Recommendation: We recommended that the City implement policies and procedures to file required reports such as the CAPER and Section 15011 report timely. View of Responsible Officials: Management is in agreement with the Finding.
2022-002 Procurement and Suspension, and Debarment ? Internal Control over Verification Against the System for Award Management (?SAM?) Identification of the Federal Programs: Assistance Listing Number: 21.027 Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Federal Agency: Department of Treasury Federal Award Number and Award Year: 2021 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Suspension and Debarment, Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a nonprocurement 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 nonprocurement transactions entered into by a recipient (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/portal/public/SAM/ (Note: The OMB guidance at 2 CFR part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (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 audit, we noted that the City did not have documentation on verifying the vendors against the SAM prior entering into contracts with the vendors to ensure that they were not suspended or debarred from federally funded purchases. Cause: The City does not have a process to train new staff on documentation of performing suspension or debarment checks on vendors that the City entered into contracts with for federally-funded projects. Effect or Potential Effect: Without verifying whether vendors are suspended or debarred from working on federally-funded projects, the City could be contracting with vendors that are prohibited from working on federally-funded projects. Questioned Costs: None. Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommended the City establish internal control procedures to document its suspension and debarment check to ensure vendors are not suspended or debarred from federally-funded purchases. View of Responsible Officials: Management concurs the finding.
Information of the Federal Programs: Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grants / Entitlement Grants Federal Agency: Department of Housing and Urban Development Federal Award Number and Award Year: B-20-MC-06-0559, B-20-MW-06-0559, and B-21-MC-06-0559 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to the Guidance on Consolidated Annual Performance and Evaluation Report (?CAPER?) (24 CFR 91.520). Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Section IV.B.2.(c) of the CDBG-CV Notice reiterated the waiver authorized by a May 7, 2020, HUD memorandum (found in the waiver information link noted in IV. Other Information, below) that waives the 90 day requirement for program year 2019 annual performance and evaluation reports, subject to the condition that within 180 days after the evaluation reports, subject to the condition that within 180 days after the close of a jurisdiction?s program year that it submit its performance report. Auditors are only expected to test information extracted from IDIS in the following system-generated reports and which include (1) PR26 ? CDBG Financial Summary Report (?PR26?). A grantee?s CAPER, submitted through the IDIS e-Con Planning Suite, is due 90 days after the close of a jurisdiction?s program year. Pursuant to Guidance on Section 15011 of the CARES Act requires that recipients of $150,000 or more of CARES Act funding submit, not later than 10 days after the end of each calendar quarter, a report containing: information regarding the amount of funds received; the amount of funds obligated or expended for each project or activity; a detailed list of all such projects or activities, including a description of the project or activity; and detailed information on any subcontracts or subgrants awarded by the recipient. This report is limited to CDBG-CV funding and does not include other CDBG funds that may be used to address coronavirus. Grantees and subrecipients have reported data meeting the Section 15011 requirements at usaspending.gov. The Pandemic Response Accountability Committee (PRAC), an independent oversight committee within the Council of the Inspectors General on Integrity and Efficiency, has determined that the data reported in usaspending.gov has fulfilled these reporting requests. (?Section 15011 Report?). Condition: The City did not submit the CAPER on time. The CAPER was submitted on November 28, 2022. In addition, the City did not submit Section 15011 report for the year ended June 30, 2022. Cause: The City staff was unavailable prior to the due date of September 30, 2022 to ensure filing CAPER timely. In addition, the City was not aware of the Section 15011 reporting requirement. Effect or Potential Effect: Delay in filing and not filing the reports resulted in noncompliance with the compliance requirements. Questioned Costs: None. Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: Repeated finding as 2021-001. Recommendation: We recommended that the City implement policies and procedures to file required reports such as the CAPER and Section 15011 report timely. View of Responsible Officials: Management is in agreement with the Finding.
Information of the Federal Programs: Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grants / Entitlement Grants Federal Agency: Department of Housing and Urban Development Federal Award Number and Award Year: B-20-MC-06-0559, B-20-MW-06-0559, and B-21-MC-06-0559 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to the Guidance on Consolidated Annual Performance and Evaluation Report (?CAPER?) (24 CFR 91.520). Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Section IV.B.2.(c) of the CDBG-CV Notice reiterated the waiver authorized by a May 7, 2020, HUD memorandum (found in the waiver information link noted in IV. Other Information, below) that waives the 90 day requirement for program year 2019 annual performance and evaluation reports, subject to the condition that within 180 days after the evaluation reports, subject to the condition that within 180 days after the close of a jurisdiction?s program year that it submit its performance report. Auditors are only expected to test information extracted from IDIS in the following system-generated reports and which include (1) PR26 ? CDBG Financial Summary Report (?PR26?). A grantee?s CAPER, submitted through the IDIS e-Con Planning Suite, is due 90 days after the close of a jurisdiction?s program year. Pursuant to Guidance on Section 15011 of the CARES Act requires that recipients of $150,000 or more of CARES Act funding submit, not later than 10 days after the end of each calendar quarter, a report containing: information regarding the amount of funds received; the amount of funds obligated or expended for each project or activity; a detailed list of all such projects or activities, including a description of the project or activity; and detailed information on any subcontracts or subgrants awarded by the recipient. This report is limited to CDBG-CV funding and does not include other CDBG funds that may be used to address coronavirus. Grantees and subrecipients have reported data meeting the Section 15011 requirements at usaspending.gov. The Pandemic Response Accountability Committee (PRAC), an independent oversight committee within the Council of the Inspectors General on Integrity and Efficiency, has determined that the data reported in usaspending.gov has fulfilled these reporting requests. (?Section 15011 Report?). Condition: The City did not submit the CAPER on time. The CAPER was submitted on November 28, 2022. In addition, the City did not submit Section 15011 report for the year ended June 30, 2022. Cause: The City staff was unavailable prior to the due date of September 30, 2022 to ensure filing CAPER timely. In addition, the City was not aware of the Section 15011 reporting requirement. Effect or Potential Effect: Delay in filing and not filing the reports resulted in noncompliance with the compliance requirements. Questioned Costs: None. Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: Repeated finding as 2021-001. Recommendation: We recommended that the City implement policies and procedures to file required reports such as the CAPER and Section 15011 report timely. View of Responsible Officials: Management is in agreement with the Finding.
2022-002 Procurement and Suspension, and Debarment ? Internal Control over Verification Against the System for Award Management (?SAM?) Identification of the Federal Programs: Assistance Listing Number: 21.027 Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Federal Agency: Department of Treasury Federal Award Number and Award Year: 2021 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Suspension and Debarment, Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a nonprocurement 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 nonprocurement transactions entered into by a recipient (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/portal/public/SAM/ (Note: The OMB guidance at 2 CFR part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (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 audit, we noted that the City did not have documentation on verifying the vendors against the SAM prior entering into contracts with the vendors to ensure that they were not suspended or debarred from federally funded purchases. Cause: The City does not have a process to train new staff on documentation of performing suspension or debarment checks on vendors that the City entered into contracts with for federally-funded projects. Effect or Potential Effect: Without verifying whether vendors are suspended or debarred from working on federally-funded projects, the City could be contracting with vendors that are prohibited from working on federally-funded projects. Questioned Costs: None. Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommended the City establish internal control procedures to document its suspension and debarment check to ensure vendors are not suspended or debarred from federally-funded purchases. View of Responsible Officials: Management concurs the finding.
Information of the Federal Programs: Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grants / Entitlement Grants Federal Agency: Department of Housing and Urban Development Federal Award Number and Award Year: B-20-MC-06-0559, B-20-MW-06-0559, and B-21-MC-06-0559 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to the Guidance on Consolidated Annual Performance and Evaluation Report (?CAPER?) (24 CFR 91.520). Integrated Disbursement and Information System (IDIS) (OMB No. 2506-0077) ? Grantees may include reports generated by IDIS as part of their annual performance and evaluation report that must be submitted for the CDBG Entitlement program 90 days after the end of a grantee?s program year. Section IV.B.2.(c) of the CDBG-CV Notice reiterated the waiver authorized by a May 7, 2020, HUD memorandum (found in the waiver information link noted in IV. Other Information, below) that waives the 90 day requirement for program year 2019 annual performance and evaluation reports, subject to the condition that within 180 days after the evaluation reports, subject to the condition that within 180 days after the close of a jurisdiction?s program year that it submit its performance report. Auditors are only expected to test information extracted from IDIS in the following system-generated reports and which include (1) PR26 ? CDBG Financial Summary Report (?PR26?). A grantee?s CAPER, submitted through the IDIS e-Con Planning Suite, is due 90 days after the close of a jurisdiction?s program year. Pursuant to Guidance on Section 15011 of the CARES Act requires that recipients of $150,000 or more of CARES Act funding submit, not later than 10 days after the end of each calendar quarter, a report containing: information regarding the amount of funds received; the amount of funds obligated or expended for each project or activity; a detailed list of all such projects or activities, including a description of the project or activity; and detailed information on any subcontracts or subgrants awarded by the recipient. This report is limited to CDBG-CV funding and does not include other CDBG funds that may be used to address coronavirus. Grantees and subrecipients have reported data meeting the Section 15011 requirements at usaspending.gov. The Pandemic Response Accountability Committee (PRAC), an independent oversight committee within the Council of the Inspectors General on Integrity and Efficiency, has determined that the data reported in usaspending.gov has fulfilled these reporting requests. (?Section 15011 Report?). Condition: The City did not submit the CAPER on time. The CAPER was submitted on November 28, 2022. In addition, the City did not submit Section 15011 report for the year ended June 30, 2022. Cause: The City staff was unavailable prior to the due date of September 30, 2022 to ensure filing CAPER timely. In addition, the City was not aware of the Section 15011 reporting requirement. Effect or Potential Effect: Delay in filing and not filing the reports resulted in noncompliance with the compliance requirements. Questioned Costs: None. Context: See condition above for context of the finding. Identification as a Repeat Finding, If Applicable: Repeated finding as 2021-001. Recommendation: We recommended that the City implement policies and procedures to file required reports such as the CAPER and Section 15011 report timely. View of Responsible Officials: Management is in agreement with the Finding.