2022 ?003- FFATA Reporting Federal agency: U.S. Department of Housing and Urban Development Federal program title: Community Development Block Grant Federal Award Identification Number and Year: B-17-UC-12-0007, B-18-UC-12-0007, B-19-UC-12-0007, B-20-UC-12-0007, B-21-UC-12-0007, and B-20-UW-12-0007 Assistance Listing Number: 14.218 Award Period: October 2017 through September 2028 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The reporting requirements under the CDBG Entitlement Cluster include financial reporting, performance reporting, and special reporting for Federal Funding Accountability and Transparency Act (FFATA). Reports are to be completed and submitted within the prescribed time period noted in each contract agreement term. The requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) are referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: There are 27 subrecipient agreements over the FFATA reporting threshold of $30,000 under the CDBG program. The auditors made a sample selection of 7 awards for testing. The 7 selected subaward contracts were tested against data reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). As reflected in the chart, there were 4 contract agreements that were not reported in FSRS. Of the remaining 3 contracts that were reported in FSRS, 2 had incorrect contract value amounts and all 3 had additional key element data inputs with errors. Questioned costs: None Context: In a statistically valid sample of 7 subrecipient contracts, the chart below illustrates the results. Transactions Tested Subaward not Reported Report not Timely Subaward Amount Incorrect Subaward Missing Key Elements Count 7 4 3 2 3 Dollar Value $1,626,363 $328,113 $1,298,250 $410,000 $1,298,250 Cause: The full extent of the FFATA reporting requirements under this grant were not properly understood by all applicable members of the grant team. Effect: The intent of FFATA subaward reporting is to provide a single searchable website that contains information on all Federal awards. The reports are submitted through the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). A failure to report the subawards can cause inaccurate information to be reported on and used by decision makers. In addition, the grantor could hold back payment near the close out if compliance is not satisfied. Repeat Finding: Yes-see 2021-002 Recommendation: We recommend the County's management reviews applicable award agreements or contracts for specific reporting requirements and establishes a reporting calendar for review and approval. We recommend the assigned personnel performing the inputs into FSRS obtain proper training of the system to ensure accuracy of data reported. We recommend knowledgeable supervisors review and approve reports for completeness and accuracy, including comparing to source documentation (general ledger, third party evidence or other reliable records) and any reconciliations between source data to final reporting. Views of responsible officials: There is no disagreement with the audit finding.
2022 ?003- FFATA Reporting Federal agency: U.S. Department of Housing and Urban Development Federal program title: Community Development Block Grant Federal Award Identification Number and Year: B-17-UC-12-0007, B-18-UC-12-0007, B-19-UC-12-0007, B-20-UC-12-0007, B-21-UC-12-0007, and B-20-UW-12-0007 Assistance Listing Number: 14.218 Award Period: October 2017 through September 2028 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The reporting requirements under the CDBG Entitlement Cluster include financial reporting, performance reporting, and special reporting for Federal Funding Accountability and Transparency Act (FFATA). Reports are to be completed and submitted within the prescribed time period noted in each contract agreement term. The requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) are referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: There are 27 subrecipient agreements over the FFATA reporting threshold of $30,000 under the CDBG program. The auditors made a sample selection of 7 awards for testing. The 7 selected subaward contracts were tested against data reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). As reflected in the chart, there were 4 contract agreements that were not reported in FSRS. Of the remaining 3 contracts that were reported in FSRS, 2 had incorrect contract value amounts and all 3 had additional key element data inputs with errors. Questioned costs: None Context: In a statistically valid sample of 7 subrecipient contracts, the chart below illustrates the results. Transactions Tested Subaward not Reported Report not Timely Subaward Amount Incorrect Subaward Missing Key Elements Count 7 4 3 2 3 Dollar Value $1,626,363 $328,113 $1,298,250 $410,000 $1,298,250 Cause: The full extent of the FFATA reporting requirements under this grant were not properly understood by all applicable members of the grant team. Effect: The intent of FFATA subaward reporting is to provide a single searchable website that contains information on all Federal awards. The reports are submitted through the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). A failure to report the subawards can cause inaccurate information to be reported on and used by decision makers. In addition, the grantor could hold back payment near the close out if compliance is not satisfied. Repeat Finding: Yes-see 2021-002 Recommendation: We recommend the County's management reviews applicable award agreements or contracts for specific reporting requirements and establishes a reporting calendar for review and approval. We recommend the assigned personnel performing the inputs into FSRS obtain proper training of the system to ensure accuracy of data reported. We recommend knowledgeable supervisors review and approve reports for completeness and accuracy, including comparing to source documentation (general ledger, third party evidence or other reliable records) and any reconciliations between source data to final reporting. Views of responsible officials: There is no disagreement with the audit finding.
2022 ?003- FFATA Reporting Federal agency: U.S. Department of Housing and Urban Development Federal program title: Community Development Block Grant Federal Award Identification Number and Year: B-17-UC-12-0007, B-18-UC-12-0007, B-19-UC-12-0007, B-20-UC-12-0007, B-21-UC-12-0007, and B-20-UW-12-0007 Assistance Listing Number: 14.218 Award Period: October 2017 through September 2028 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The reporting requirements under the CDBG Entitlement Cluster include financial reporting, performance reporting, and special reporting for Federal Funding Accountability and Transparency Act (FFATA). Reports are to be completed and submitted within the prescribed time period noted in each contract agreement term. The requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) are referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: There are 27 subrecipient agreements over the FFATA reporting threshold of $30,000 under the CDBG program. The auditors made a sample selection of 7 awards for testing. The 7 selected subaward contracts were tested against data reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). As reflected in the chart, there were 4 contract agreements that were not reported in FSRS. Of the remaining 3 contracts that were reported in FSRS, 2 had incorrect contract value amounts and all 3 had additional key element data inputs with errors. Questioned costs: None Context: In a statistically valid sample of 7 subrecipient contracts, the chart below illustrates the results. Transactions Tested Subaward not Reported Report not Timely Subaward Amount Incorrect Subaward Missing Key Elements Count 7 4 3 2 3 Dollar Value $1,626,363 $328,113 $1,298,250 $410,000 $1,298,250 Cause: The full extent of the FFATA reporting requirements under this grant were not properly understood by all applicable members of the grant team. Effect: The intent of FFATA subaward reporting is to provide a single searchable website that contains information on all Federal awards. The reports are submitted through the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). A failure to report the subawards can cause inaccurate information to be reported on and used by decision makers. In addition, the grantor could hold back payment near the close out if compliance is not satisfied. Repeat Finding: Yes-see 2021-002 Recommendation: We recommend the County's management reviews applicable award agreements or contracts for specific reporting requirements and establishes a reporting calendar for review and approval. We recommend the assigned personnel performing the inputs into FSRS obtain proper training of the system to ensure accuracy of data reported. We recommend knowledgeable supervisors review and approve reports for completeness and accuracy, including comparing to source documentation (general ledger, third party evidence or other reliable records) and any reconciliations between source data to final reporting. Views of responsible officials: There is no disagreement with the audit finding.
2022 ?003- FFATA Reporting Federal agency: U.S. Department of Housing and Urban Development Federal program title: Community Development Block Grant Federal Award Identification Number and Year: B-17-UC-12-0007, B-18-UC-12-0007, B-19-UC-12-0007, B-20-UC-12-0007, B-21-UC-12-0007, and B-20-UW-12-0007 Assistance Listing Number: 14.218 Award Period: October 2017 through September 2028 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The reporting requirements under the CDBG Entitlement Cluster include financial reporting, performance reporting, and special reporting for Federal Funding Accountability and Transparency Act (FFATA). Reports are to be completed and submitted within the prescribed time period noted in each contract agreement term. The requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) are referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: There are 27 subrecipient agreements over the FFATA reporting threshold of $30,000 under the CDBG program. The auditors made a sample selection of 7 awards for testing. The 7 selected subaward contracts were tested against data reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). As reflected in the chart, there were 4 contract agreements that were not reported in FSRS. Of the remaining 3 contracts that were reported in FSRS, 2 had incorrect contract value amounts and all 3 had additional key element data inputs with errors. Questioned costs: None Context: In a statistically valid sample of 7 subrecipient contracts, the chart below illustrates the results. Transactions Tested Subaward not Reported Report not Timely Subaward Amount Incorrect Subaward Missing Key Elements Count 7 4 3 2 3 Dollar Value $1,626,363 $328,113 $1,298,250 $410,000 $1,298,250 Cause: The full extent of the FFATA reporting requirements under this grant were not properly understood by all applicable members of the grant team. Effect: The intent of FFATA subaward reporting is to provide a single searchable website that contains information on all Federal awards. The reports are submitted through the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). A failure to report the subawards can cause inaccurate information to be reported on and used by decision makers. In addition, the grantor could hold back payment near the close out if compliance is not satisfied. Repeat Finding: Yes-see 2021-002 Recommendation: We recommend the County's management reviews applicable award agreements or contracts for specific reporting requirements and establishes a reporting calendar for review and approval. We recommend the assigned personnel performing the inputs into FSRS obtain proper training of the system to ensure accuracy of data reported. We recommend knowledgeable supervisors review and approve reports for completeness and accuracy, including comparing to source documentation (general ledger, third party evidence or other reliable records) and any reconciliations between source data to final reporting. Views of responsible officials: There is no disagreement with the audit finding.
2022 ?003- FFATA Reporting Federal agency: U.S. Department of Housing and Urban Development Federal program title: Community Development Block Grant Federal Award Identification Number and Year: B-17-UC-12-0007, B-18-UC-12-0007, B-19-UC-12-0007, B-20-UC-12-0007, B-21-UC-12-0007, and B-20-UW-12-0007 Assistance Listing Number: 14.218 Award Period: October 2017 through September 2028 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The reporting requirements under the CDBG Entitlement Cluster include financial reporting, performance reporting, and special reporting for Federal Funding Accountability and Transparency Act (FFATA). Reports are to be completed and submitted within the prescribed time period noted in each contract agreement term. The requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) are referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: There are 27 subrecipient agreements over the FFATA reporting threshold of $30,000 under the CDBG program. The auditors made a sample selection of 7 awards for testing. The 7 selected subaward contracts were tested against data reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). As reflected in the chart, there were 4 contract agreements that were not reported in FSRS. Of the remaining 3 contracts that were reported in FSRS, 2 had incorrect contract value amounts and all 3 had additional key element data inputs with errors. Questioned costs: None Context: In a statistically valid sample of 7 subrecipient contracts, the chart below illustrates the results. Transactions Tested Subaward not Reported Report not Timely Subaward Amount Incorrect Subaward Missing Key Elements Count 7 4 3 2 3 Dollar Value $1,626,363 $328,113 $1,298,250 $410,000 $1,298,250 Cause: The full extent of the FFATA reporting requirements under this grant were not properly understood by all applicable members of the grant team. Effect: The intent of FFATA subaward reporting is to provide a single searchable website that contains information on all Federal awards. The reports are submitted through the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). A failure to report the subawards can cause inaccurate information to be reported on and used by decision makers. In addition, the grantor could hold back payment near the close out if compliance is not satisfied. Repeat Finding: Yes-see 2021-002 Recommendation: We recommend the County's management reviews applicable award agreements or contracts for specific reporting requirements and establishes a reporting calendar for review and approval. We recommend the assigned personnel performing the inputs into FSRS obtain proper training of the system to ensure accuracy of data reported. We recommend knowledgeable supervisors review and approve reports for completeness and accuracy, including comparing to source documentation (general ledger, third party evidence or other reliable records) and any reconciliations between source data to final reporting. Views of responsible officials: There is no disagreement with the audit finding.
2022 ?003- FFATA Reporting Federal agency: U.S. Department of Housing and Urban Development Federal program title: Community Development Block Grant Federal Award Identification Number and Year: B-17-UC-12-0007, B-18-UC-12-0007, B-19-UC-12-0007, B-20-UC-12-0007, B-21-UC-12-0007, and B-20-UW-12-0007 Assistance Listing Number: 14.218 Award Period: October 2017 through September 2028 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The reporting requirements under the CDBG Entitlement Cluster include financial reporting, performance reporting, and special reporting for Federal Funding Accountability and Transparency Act (FFATA). Reports are to be completed and submitted within the prescribed time period noted in each contract agreement term. The requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) are referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: There are 27 subrecipient agreements over the FFATA reporting threshold of $30,000 under the CDBG program. The auditors made a sample selection of 7 awards for testing. The 7 selected subaward contracts were tested against data reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). As reflected in the chart, there were 4 contract agreements that were not reported in FSRS. Of the remaining 3 contracts that were reported in FSRS, 2 had incorrect contract value amounts and all 3 had additional key element data inputs with errors. Questioned costs: None Context: In a statistically valid sample of 7 subrecipient contracts, the chart below illustrates the results. Transactions Tested Subaward not Reported Report not Timely Subaward Amount Incorrect Subaward Missing Key Elements Count 7 4 3 2 3 Dollar Value $1,626,363 $328,113 $1,298,250 $410,000 $1,298,250 Cause: The full extent of the FFATA reporting requirements under this grant were not properly understood by all applicable members of the grant team. Effect: The intent of FFATA subaward reporting is to provide a single searchable website that contains information on all Federal awards. The reports are submitted through the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). A failure to report the subawards can cause inaccurate information to be reported on and used by decision makers. In addition, the grantor could hold back payment near the close out if compliance is not satisfied. Repeat Finding: Yes-see 2021-002 Recommendation: We recommend the County's management reviews applicable award agreements or contracts for specific reporting requirements and establishes a reporting calendar for review and approval. We recommend the assigned personnel performing the inputs into FSRS obtain proper training of the system to ensure accuracy of data reported. We recommend knowledgeable supervisors review and approve reports for completeness and accuracy, including comparing to source documentation (general ledger, third party evidence or other reliable records) and any reconciliations between source data to final reporting. Views of responsible officials: There is no disagreement with the audit finding.
2022-005-Reporting Federal Agency: U.S. Department of the Treasury Federal Program Name: Covid-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number: Z1890 Award Period: March 3, 2021 through December 31, 2026 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The U.S. Treasury Department's current version of its Coronavirus State and Local Fiscal Recovery Funds Guidance on Recipient Compliance and Reporting Responsibilities (collectively, the "SLFRF Guidance") provides information on the reporting requirements of the program. During the audit period, the Interim Report and quarterly Project and Expenditure Reports were required under this guidance. Condition: The quarterly Project and Expenditure Reports contain key line items under the following three subcategories: 1) Obligations and Expenditures, 2) Subawards, and 3) Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. Questioned costs: N/A Context: The auditors selected and tested a statistically valid sample of 10 organizations reported on the interim report and all 4 quarterly reports until a total sample of 40 items were tested. See the chart below for identified exceptions. Exception Type Number of Items Tested Number of Exceptions Missing key line-item data excluded from quarterly report 8 8 Entity type (subrecipient, beneficiary, contractor) reported was not accurate 40 23 Expenditure amount did not agree to schedule of expenditures 40 6 Obligated amounts per Organization?s contract did not agree with value reported as obligated on quarterly reports 40 40 Obligated amount was not reported in a timely manner 40 2 Cause: The key personnel assigned to reporting did not fully understand the distinction between subrecipients, contractors, and beneficiaries. Additionally, the nuances of the reporting portal caused errors for reporting obligations verse expenditures and therefore obligations reported had errors. Effect: Inaccurate data reported to the Treasury could impact the allowed funding the County can earn for these funds. Repeat Finding: No. Recommendation: We recommend corrections to quarterly reports be made in subsequent quarterly reports to ensure obligations match actuality. We recommend timely reconciliation of accounting transactions to allow for accurate reporting of expenditures through the quarter. Additionally, we recommend careful consideration of assignment for type of entity for which the County enters transactions with related to this funding. Views of responsible officials: There is no disagreement with the audit finding.
2022-006-Revenue Loss Calculation Federal Agency: U.S. Department of the Treasury Federal Program Name: Covid-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number: Z1890 Award Period: March 3, 2021 through December 31, 2026 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Coronavirus State and Local Fiscal Recovery Funds (CSLFR) provide needed fiscal relief for recipients that have experienced revenue loss due to the onset of the COVID-19 public health emergency. Specifically, SLFRF funding may be used to pay for ?government services? in an amount equal to the revenue loss experienced by the recipient due to the COVID-19 public health emergency. Government services generally include any service traditionally provided by a government, including construction of roads and other infrastructure, provision of public safety and other services, and health and educational services. Funds spent under government services are subject to streamlined reporting and compliance requirements. In order to use funds under government services, recipients should first determine revenue loss. The Treasury's final rule provides the guidance for how revenue loss is calculated. Condition: The revenue loss calculation was not calculated in accordance with the guidance provided by the Treasury?s Final Rule. Questioned costs: N/A Context: The original revenue loss calculation allowed for loss revenue provisions of approximately $31 million. The corrected and revised calculation was approximately $29 million. Cause: The key roles assigned to doing this calculation experienced turnover. In addition, certain accounts were included in the calculation that should not have been included resulting in a lower loss revenue amount. Effect: The original calculation resulted a Coronavirus State and Local Fiscal Recovery Funds budget that included an amount for revenue loss that was higher than what is allowable by the Treasury?s Final Rule. Repeat Finding: No. Recommendation: We recommend the County designate a reviewer to perform a detailed review of future revenue loss calculations to ensure the calculation complies with the requirements of the Treasury?s Final Rule. Views of responsible officials: There is no disagreement with the audit finding.
2022-007-Subrecipient Monitoring Federal Agency: U.S. Department of the Treasury Federal Program Name: Covid-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number: Z1890 Award Period: March 3, 2021, through December 31, 2026 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR section 200.332(a) notes pass-through entities such as Polk County, Florida need to ensure that every subaward is clearly identified to the subrecipient as a subaward and includes required information at the time of the subaward sufficient for the subrecipient to comply with federal statutes, regulation, and the terms and conditions of the award. If any of the data elements change the impact should be updated in subsequent subaward modification. 2 CFR section 200.332(b)-(f) covers required monitoring activities and management of subrecipient relationships that should be performed by the pass-through entity. Condition: During the testing of quarterly Project and Expenditure Reports submitted to the Treasury, information included for contracts and subawards was not agreeing to information reported on the Schedule of Expenditures of Federal Awards (SEFA). Auditors selected reported subrecipients, beneficiaries, and contractors to determine the validity of assigned category. A subrecipient is an entity that receives a subaward to carry out a project funded by Fiscal Recovery Funds on behalf of a recipient. Individuals or entities that are direct beneficiaries of a project funded by Fiscal Recovery Funds are not considered subrecipients. Households, communities, small businesses, nonprofits, and impacted industries are all potential beneficiaries of projects carried out with SLFRF funds. The terms and conditions of Federal awards flow down to subawards to subrecipients, requiring subrecipients to comply with all requirements of recipients such as the treatment of eligible uses of funds, procurement, and reporting requirements. Beneficiaries are not subject to the requirements placed on subrecipients in the Uniform Guidance. The distinction between a subrecipient and a beneficiary, therefore, is contingent upon the rationale for why a recipient is providing funds to the individual or entity. If the recipient is providing funds to the individual or entity for the purpose of carrying out a SLFRF program or project on behalf of the recipient, the individual or entity is acting as a subrecipient. Acting as a subrecipient, the individual or entity is subject to subrecipient monitoring and reporting requirements. Questioned costs: N/A Context: A statistically valid sample of 10 organizations listed on each of the quarterly Treasury reports (40 total items tested) was selected and tested against the entity-type determination criteria. In the sample of 40 entity types reported, there were twenty-three exceptions (23) which resulted in a conclusion that only one (1) Organization reported was truly a subrecipient. This subrecipient was not captured on the SEFA and the elements of monitoring were not in place. The review of the contract agreement between Polk County and this subrecipient did not meet all requirements under 2 CFR section 200.332(a). Cause: The distinction between the entity types receiving this federal funding was not fully understood by personnel. Effect: Recipients and subrecipients are the first line of defense and responsible for ensuring the SLFRF award funds are not used for ineligible purposes, and there is no fraud, waste, or abuse associated with their SLFRF award. The terms and conditions of Federal awards flow down to subawards to subrecipients, requiring subrecipients to comply with all requirements of recipients such as the treatment of eligible uses of funds, procurement, and reporting requirements. A lack of monitoring can lead to noncompliance by the subrecipient which ultimately impacts the compliance of the pass-through entity. Repeat Finding: No. Recommendation: We recommend an amended subrecipient contract that complies with all guidelines under 2 CFR section 200.332(a) be put into place between Polk County and the identified subrecipient. In addition, we recommend a risk assessment of this subrecipient be performed and depending on the results of the assessment, determine a planned schedule of monitoring that matches frequency and intensity that aligns with the risk assessment. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004-Controls Over Reporting Federal Agency: U.S. Department of the Treasury Federal Program Name: Covid-19 Emergency Rental Assistance Assistance Listing Number: 21.023 Federal Award Identification Number: 1505-0266 and 1505-0270 Award Period: September 30, 2021-September 30, 2022, for ERA1 and May 10, 2021 through September 30, 2025 for ERA 2 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: As a condition of receiving federal awards, non-federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to also maintain internal control to provide reasonable assurance of compliance within these requirements. The County management is responsible for establishing and maintaining internal controls over grants. Condition/Context: Auditor selected and tested a statistically valid sample of 5 financial reports and 8 performance reports from the audit period. There was no evidence of review performed on any of the 13 reports. Questioned costs: N/A Cause: During the audit period there was turnover in grant management. Reports that were previously prepared by a knowledgeable member and then reviewed by the HND Manager discontinued to be reviewed after the departure of the HND Manager. There was no assigned replacement for the review process since the original preparer ultimately was promoted into the HND Manager roll. Effect: A lack of review can cause errors to go undetected in the reporting to the grantor. Repeat Finding: No Recommendation: We recommend the County review Government Finance Officers Association's (GFOA) Best Practices for Internal Control for Grants published September 1, 2022, and update internal processes to ensure tasks and review of tasks continue even during periods of staff turnover or vacancies. The County should consider cross-training personnel to allow preparation of certain reports to be prepared and reviewed by separate knowledgeable individuals. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004-Controls Over Reporting Federal Agency: U.S. Department of the Treasury Federal Program Name: Covid-19 Emergency Rental Assistance Assistance Listing Number: 21.023 Federal Award Identification Number: 1505-0266 and 1505-0270 Award Period: September 30, 2021-September 30, 2022, for ERA1 and May 10, 2021 through September 30, 2025 for ERA 2 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: As a condition of receiving federal awards, non-federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to also maintain internal control to provide reasonable assurance of compliance within these requirements. The County management is responsible for establishing and maintaining internal controls over grants. Condition/Context: Auditor selected and tested a statistically valid sample of 5 financial reports and 8 performance reports from the audit period. There was no evidence of review performed on any of the 13 reports. Questioned costs: N/A Cause: During the audit period there was turnover in grant management. Reports that were previously prepared by a knowledgeable member and then reviewed by the HND Manager discontinued to be reviewed after the departure of the HND Manager. There was no assigned replacement for the review process since the original preparer ultimately was promoted into the HND Manager roll. Effect: A lack of review can cause errors to go undetected in the reporting to the grantor. Repeat Finding: No Recommendation: We recommend the County review Government Finance Officers Association's (GFOA) Best Practices for Internal Control for Grants published September 1, 2022, and update internal processes to ensure tasks and review of tasks continue even during periods of staff turnover or vacancies. The County should consider cross-training personnel to allow preparation of certain reports to be prepared and reviewed by separate knowledgeable individuals. Views of responsible officials: There is no disagreement with the audit finding.
2022 ?003- FFATA Reporting Federal agency: U.S. Department of Housing and Urban Development Federal program title: Community Development Block Grant Federal Award Identification Number and Year: B-17-UC-12-0007, B-18-UC-12-0007, B-19-UC-12-0007, B-20-UC-12-0007, B-21-UC-12-0007, and B-20-UW-12-0007 Assistance Listing Number: 14.218 Award Period: October 2017 through September 2028 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The reporting requirements under the CDBG Entitlement Cluster include financial reporting, performance reporting, and special reporting for Federal Funding Accountability and Transparency Act (FFATA). Reports are to be completed and submitted within the prescribed time period noted in each contract agreement term. The requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) are referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: There are 27 subrecipient agreements over the FFATA reporting threshold of $30,000 under the CDBG program. The auditors made a sample selection of 7 awards for testing. The 7 selected subaward contracts were tested against data reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). As reflected in the chart, there were 4 contract agreements that were not reported in FSRS. Of the remaining 3 contracts that were reported in FSRS, 2 had incorrect contract value amounts and all 3 had additional key element data inputs with errors. Questioned costs: None Context: In a statistically valid sample of 7 subrecipient contracts, the chart below illustrates the results. Transactions Tested Subaward not Reported Report not Timely Subaward Amount Incorrect Subaward Missing Key Elements Count 7 4 3 2 3 Dollar Value $1,626,363 $328,113 $1,298,250 $410,000 $1,298,250 Cause: The full extent of the FFATA reporting requirements under this grant were not properly understood by all applicable members of the grant team. Effect: The intent of FFATA subaward reporting is to provide a single searchable website that contains information on all Federal awards. The reports are submitted through the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). A failure to report the subawards can cause inaccurate information to be reported on and used by decision makers. In addition, the grantor could hold back payment near the close out if compliance is not satisfied. Repeat Finding: Yes-see 2021-002 Recommendation: We recommend the County's management reviews applicable award agreements or contracts for specific reporting requirements and establishes a reporting calendar for review and approval. We recommend the assigned personnel performing the inputs into FSRS obtain proper training of the system to ensure accuracy of data reported. We recommend knowledgeable supervisors review and approve reports for completeness and accuracy, including comparing to source documentation (general ledger, third party evidence or other reliable records) and any reconciliations between source data to final reporting. Views of responsible officials: There is no disagreement with the audit finding.
2022 ?003- FFATA Reporting Federal agency: U.S. Department of Housing and Urban Development Federal program title: Community Development Block Grant Federal Award Identification Number and Year: B-17-UC-12-0007, B-18-UC-12-0007, B-19-UC-12-0007, B-20-UC-12-0007, B-21-UC-12-0007, and B-20-UW-12-0007 Assistance Listing Number: 14.218 Award Period: October 2017 through September 2028 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The reporting requirements under the CDBG Entitlement Cluster include financial reporting, performance reporting, and special reporting for Federal Funding Accountability and Transparency Act (FFATA). Reports are to be completed and submitted within the prescribed time period noted in each contract agreement term. The requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) are referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: There are 27 subrecipient agreements over the FFATA reporting threshold of $30,000 under the CDBG program. The auditors made a sample selection of 7 awards for testing. The 7 selected subaward contracts were tested against data reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). As reflected in the chart, there were 4 contract agreements that were not reported in FSRS. Of the remaining 3 contracts that were reported in FSRS, 2 had incorrect contract value amounts and all 3 had additional key element data inputs with errors. Questioned costs: None Context: In a statistically valid sample of 7 subrecipient contracts, the chart below illustrates the results. Transactions Tested Subaward not Reported Report not Timely Subaward Amount Incorrect Subaward Missing Key Elements Count 7 4 3 2 3 Dollar Value $1,626,363 $328,113 $1,298,250 $410,000 $1,298,250 Cause: The full extent of the FFATA reporting requirements under this grant were not properly understood by all applicable members of the grant team. Effect: The intent of FFATA subaward reporting is to provide a single searchable website that contains information on all Federal awards. The reports are submitted through the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). A failure to report the subawards can cause inaccurate information to be reported on and used by decision makers. In addition, the grantor could hold back payment near the close out if compliance is not satisfied. Repeat Finding: Yes-see 2021-002 Recommendation: We recommend the County's management reviews applicable award agreements or contracts for specific reporting requirements and establishes a reporting calendar for review and approval. We recommend the assigned personnel performing the inputs into FSRS obtain proper training of the system to ensure accuracy of data reported. We recommend knowledgeable supervisors review and approve reports for completeness and accuracy, including comparing to source documentation (general ledger, third party evidence or other reliable records) and any reconciliations between source data to final reporting. Views of responsible officials: There is no disagreement with the audit finding.
2022 ?003- FFATA Reporting Federal agency: U.S. Department of Housing and Urban Development Federal program title: Community Development Block Grant Federal Award Identification Number and Year: B-17-UC-12-0007, B-18-UC-12-0007, B-19-UC-12-0007, B-20-UC-12-0007, B-21-UC-12-0007, and B-20-UW-12-0007 Assistance Listing Number: 14.218 Award Period: October 2017 through September 2028 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The reporting requirements under the CDBG Entitlement Cluster include financial reporting, performance reporting, and special reporting for Federal Funding Accountability and Transparency Act (FFATA). Reports are to be completed and submitted within the prescribed time period noted in each contract agreement term. The requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) are referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: There are 27 subrecipient agreements over the FFATA reporting threshold of $30,000 under the CDBG program. The auditors made a sample selection of 7 awards for testing. The 7 selected subaward contracts were tested against data reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). As reflected in the chart, there were 4 contract agreements that were not reported in FSRS. Of the remaining 3 contracts that were reported in FSRS, 2 had incorrect contract value amounts and all 3 had additional key element data inputs with errors. Questioned costs: None Context: In a statistically valid sample of 7 subrecipient contracts, the chart below illustrates the results. Transactions Tested Subaward not Reported Report not Timely Subaward Amount Incorrect Subaward Missing Key Elements Count 7 4 3 2 3 Dollar Value $1,626,363 $328,113 $1,298,250 $410,000 $1,298,250 Cause: The full extent of the FFATA reporting requirements under this grant were not properly understood by all applicable members of the grant team. Effect: The intent of FFATA subaward reporting is to provide a single searchable website that contains information on all Federal awards. The reports are submitted through the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). A failure to report the subawards can cause inaccurate information to be reported on and used by decision makers. In addition, the grantor could hold back payment near the close out if compliance is not satisfied. Repeat Finding: Yes-see 2021-002 Recommendation: We recommend the County's management reviews applicable award agreements or contracts for specific reporting requirements and establishes a reporting calendar for review and approval. We recommend the assigned personnel performing the inputs into FSRS obtain proper training of the system to ensure accuracy of data reported. We recommend knowledgeable supervisors review and approve reports for completeness and accuracy, including comparing to source documentation (general ledger, third party evidence or other reliable records) and any reconciliations between source data to final reporting. Views of responsible officials: There is no disagreement with the audit finding.
2022 ?003- FFATA Reporting Federal agency: U.S. Department of Housing and Urban Development Federal program title: Community Development Block Grant Federal Award Identification Number and Year: B-17-UC-12-0007, B-18-UC-12-0007, B-19-UC-12-0007, B-20-UC-12-0007, B-21-UC-12-0007, and B-20-UW-12-0007 Assistance Listing Number: 14.218 Award Period: October 2017 through September 2028 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The reporting requirements under the CDBG Entitlement Cluster include financial reporting, performance reporting, and special reporting for Federal Funding Accountability and Transparency Act (FFATA). Reports are to be completed and submitted within the prescribed time period noted in each contract agreement term. The requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) are referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: There are 27 subrecipient agreements over the FFATA reporting threshold of $30,000 under the CDBG program. The auditors made a sample selection of 7 awards for testing. The 7 selected subaward contracts were tested against data reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). As reflected in the chart, there were 4 contract agreements that were not reported in FSRS. Of the remaining 3 contracts that were reported in FSRS, 2 had incorrect contract value amounts and all 3 had additional key element data inputs with errors. Questioned costs: None Context: In a statistically valid sample of 7 subrecipient contracts, the chart below illustrates the results. Transactions Tested Subaward not Reported Report not Timely Subaward Amount Incorrect Subaward Missing Key Elements Count 7 4 3 2 3 Dollar Value $1,626,363 $328,113 $1,298,250 $410,000 $1,298,250 Cause: The full extent of the FFATA reporting requirements under this grant were not properly understood by all applicable members of the grant team. Effect: The intent of FFATA subaward reporting is to provide a single searchable website that contains information on all Federal awards. The reports are submitted through the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). A failure to report the subawards can cause inaccurate information to be reported on and used by decision makers. In addition, the grantor could hold back payment near the close out if compliance is not satisfied. Repeat Finding: Yes-see 2021-002 Recommendation: We recommend the County's management reviews applicable award agreements or contracts for specific reporting requirements and establishes a reporting calendar for review and approval. We recommend the assigned personnel performing the inputs into FSRS obtain proper training of the system to ensure accuracy of data reported. We recommend knowledgeable supervisors review and approve reports for completeness and accuracy, including comparing to source documentation (general ledger, third party evidence or other reliable records) and any reconciliations between source data to final reporting. Views of responsible officials: There is no disagreement with the audit finding.
2022 ?003- FFATA Reporting Federal agency: U.S. Department of Housing and Urban Development Federal program title: Community Development Block Grant Federal Award Identification Number and Year: B-17-UC-12-0007, B-18-UC-12-0007, B-19-UC-12-0007, B-20-UC-12-0007, B-21-UC-12-0007, and B-20-UW-12-0007 Assistance Listing Number: 14.218 Award Period: October 2017 through September 2028 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The reporting requirements under the CDBG Entitlement Cluster include financial reporting, performance reporting, and special reporting for Federal Funding Accountability and Transparency Act (FFATA). Reports are to be completed and submitted within the prescribed time period noted in each contract agreement term. The requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) are referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: There are 27 subrecipient agreements over the FFATA reporting threshold of $30,000 under the CDBG program. The auditors made a sample selection of 7 awards for testing. The 7 selected subaward contracts were tested against data reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). As reflected in the chart, there were 4 contract agreements that were not reported in FSRS. Of the remaining 3 contracts that were reported in FSRS, 2 had incorrect contract value amounts and all 3 had additional key element data inputs with errors. Questioned costs: None Context: In a statistically valid sample of 7 subrecipient contracts, the chart below illustrates the results. Transactions Tested Subaward not Reported Report not Timely Subaward Amount Incorrect Subaward Missing Key Elements Count 7 4 3 2 3 Dollar Value $1,626,363 $328,113 $1,298,250 $410,000 $1,298,250 Cause: The full extent of the FFATA reporting requirements under this grant were not properly understood by all applicable members of the grant team. Effect: The intent of FFATA subaward reporting is to provide a single searchable website that contains information on all Federal awards. The reports are submitted through the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). A failure to report the subawards can cause inaccurate information to be reported on and used by decision makers. In addition, the grantor could hold back payment near the close out if compliance is not satisfied. Repeat Finding: Yes-see 2021-002 Recommendation: We recommend the County's management reviews applicable award agreements or contracts for specific reporting requirements and establishes a reporting calendar for review and approval. We recommend the assigned personnel performing the inputs into FSRS obtain proper training of the system to ensure accuracy of data reported. We recommend knowledgeable supervisors review and approve reports for completeness and accuracy, including comparing to source documentation (general ledger, third party evidence or other reliable records) and any reconciliations between source data to final reporting. Views of responsible officials: There is no disagreement with the audit finding.
2022 ?003- FFATA Reporting Federal agency: U.S. Department of Housing and Urban Development Federal program title: Community Development Block Grant Federal Award Identification Number and Year: B-17-UC-12-0007, B-18-UC-12-0007, B-19-UC-12-0007, B-20-UC-12-0007, B-21-UC-12-0007, and B-20-UW-12-0007 Assistance Listing Number: 14.218 Award Period: October 2017 through September 2028 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The reporting requirements under the CDBG Entitlement Cluster include financial reporting, performance reporting, and special reporting for Federal Funding Accountability and Transparency Act (FFATA). Reports are to be completed and submitted within the prescribed time period noted in each contract agreement term. The requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) are referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: There are 27 subrecipient agreements over the FFATA reporting threshold of $30,000 under the CDBG program. The auditors made a sample selection of 7 awards for testing. The 7 selected subaward contracts were tested against data reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). As reflected in the chart, there were 4 contract agreements that were not reported in FSRS. Of the remaining 3 contracts that were reported in FSRS, 2 had incorrect contract value amounts and all 3 had additional key element data inputs with errors. Questioned costs: None Context: In a statistically valid sample of 7 subrecipient contracts, the chart below illustrates the results. Transactions Tested Subaward not Reported Report not Timely Subaward Amount Incorrect Subaward Missing Key Elements Count 7 4 3 2 3 Dollar Value $1,626,363 $328,113 $1,298,250 $410,000 $1,298,250 Cause: The full extent of the FFATA reporting requirements under this grant were not properly understood by all applicable members of the grant team. Effect: The intent of FFATA subaward reporting is to provide a single searchable website that contains information on all Federal awards. The reports are submitted through the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). A failure to report the subawards can cause inaccurate information to be reported on and used by decision makers. In addition, the grantor could hold back payment near the close out if compliance is not satisfied. Repeat Finding: Yes-see 2021-002 Recommendation: We recommend the County's management reviews applicable award agreements or contracts for specific reporting requirements and establishes a reporting calendar for review and approval. We recommend the assigned personnel performing the inputs into FSRS obtain proper training of the system to ensure accuracy of data reported. We recommend knowledgeable supervisors review and approve reports for completeness and accuracy, including comparing to source documentation (general ledger, third party evidence or other reliable records) and any reconciliations between source data to final reporting. Views of responsible officials: There is no disagreement with the audit finding.
2022-005-Reporting Federal Agency: U.S. Department of the Treasury Federal Program Name: Covid-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number: Z1890 Award Period: March 3, 2021 through December 31, 2026 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The U.S. Treasury Department's current version of its Coronavirus State and Local Fiscal Recovery Funds Guidance on Recipient Compliance and Reporting Responsibilities (collectively, the "SLFRF Guidance") provides information on the reporting requirements of the program. During the audit period, the Interim Report and quarterly Project and Expenditure Reports were required under this guidance. Condition: The quarterly Project and Expenditure Reports contain key line items under the following three subcategories: 1) Obligations and Expenditures, 2) Subawards, and 3) Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. Questioned costs: N/A Context: The auditors selected and tested a statistically valid sample of 10 organizations reported on the interim report and all 4 quarterly reports until a total sample of 40 items were tested. See the chart below for identified exceptions. Exception Type Number of Items Tested Number of Exceptions Missing key line-item data excluded from quarterly report 8 8 Entity type (subrecipient, beneficiary, contractor) reported was not accurate 40 23 Expenditure amount did not agree to schedule of expenditures 40 6 Obligated amounts per Organization?s contract did not agree with value reported as obligated on quarterly reports 40 40 Obligated amount was not reported in a timely manner 40 2 Cause: The key personnel assigned to reporting did not fully understand the distinction between subrecipients, contractors, and beneficiaries. Additionally, the nuances of the reporting portal caused errors for reporting obligations verse expenditures and therefore obligations reported had errors. Effect: Inaccurate data reported to the Treasury could impact the allowed funding the County can earn for these funds. Repeat Finding: No. Recommendation: We recommend corrections to quarterly reports be made in subsequent quarterly reports to ensure obligations match actuality. We recommend timely reconciliation of accounting transactions to allow for accurate reporting of expenditures through the quarter. Additionally, we recommend careful consideration of assignment for type of entity for which the County enters transactions with related to this funding. Views of responsible officials: There is no disagreement with the audit finding.
2022-006-Revenue Loss Calculation Federal Agency: U.S. Department of the Treasury Federal Program Name: Covid-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number: Z1890 Award Period: March 3, 2021 through December 31, 2026 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Coronavirus State and Local Fiscal Recovery Funds (CSLFR) provide needed fiscal relief for recipients that have experienced revenue loss due to the onset of the COVID-19 public health emergency. Specifically, SLFRF funding may be used to pay for ?government services? in an amount equal to the revenue loss experienced by the recipient due to the COVID-19 public health emergency. Government services generally include any service traditionally provided by a government, including construction of roads and other infrastructure, provision of public safety and other services, and health and educational services. Funds spent under government services are subject to streamlined reporting and compliance requirements. In order to use funds under government services, recipients should first determine revenue loss. The Treasury's final rule provides the guidance for how revenue loss is calculated. Condition: The revenue loss calculation was not calculated in accordance with the guidance provided by the Treasury?s Final Rule. Questioned costs: N/A Context: The original revenue loss calculation allowed for loss revenue provisions of approximately $31 million. The corrected and revised calculation was approximately $29 million. Cause: The key roles assigned to doing this calculation experienced turnover. In addition, certain accounts were included in the calculation that should not have been included resulting in a lower loss revenue amount. Effect: The original calculation resulted a Coronavirus State and Local Fiscal Recovery Funds budget that included an amount for revenue loss that was higher than what is allowable by the Treasury?s Final Rule. Repeat Finding: No. Recommendation: We recommend the County designate a reviewer to perform a detailed review of future revenue loss calculations to ensure the calculation complies with the requirements of the Treasury?s Final Rule. Views of responsible officials: There is no disagreement with the audit finding.
2022-007-Subrecipient Monitoring Federal Agency: U.S. Department of the Treasury Federal Program Name: Covid-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number: Z1890 Award Period: March 3, 2021, through December 31, 2026 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR section 200.332(a) notes pass-through entities such as Polk County, Florida need to ensure that every subaward is clearly identified to the subrecipient as a subaward and includes required information at the time of the subaward sufficient for the subrecipient to comply with federal statutes, regulation, and the terms and conditions of the award. If any of the data elements change the impact should be updated in subsequent subaward modification. 2 CFR section 200.332(b)-(f) covers required monitoring activities and management of subrecipient relationships that should be performed by the pass-through entity. Condition: During the testing of quarterly Project and Expenditure Reports submitted to the Treasury, information included for contracts and subawards was not agreeing to information reported on the Schedule of Expenditures of Federal Awards (SEFA). Auditors selected reported subrecipients, beneficiaries, and contractors to determine the validity of assigned category. A subrecipient is an entity that receives a subaward to carry out a project funded by Fiscal Recovery Funds on behalf of a recipient. Individuals or entities that are direct beneficiaries of a project funded by Fiscal Recovery Funds are not considered subrecipients. Households, communities, small businesses, nonprofits, and impacted industries are all potential beneficiaries of projects carried out with SLFRF funds. The terms and conditions of Federal awards flow down to subawards to subrecipients, requiring subrecipients to comply with all requirements of recipients such as the treatment of eligible uses of funds, procurement, and reporting requirements. Beneficiaries are not subject to the requirements placed on subrecipients in the Uniform Guidance. The distinction between a subrecipient and a beneficiary, therefore, is contingent upon the rationale for why a recipient is providing funds to the individual or entity. If the recipient is providing funds to the individual or entity for the purpose of carrying out a SLFRF program or project on behalf of the recipient, the individual or entity is acting as a subrecipient. Acting as a subrecipient, the individual or entity is subject to subrecipient monitoring and reporting requirements. Questioned costs: N/A Context: A statistically valid sample of 10 organizations listed on each of the quarterly Treasury reports (40 total items tested) was selected and tested against the entity-type determination criteria. In the sample of 40 entity types reported, there were twenty-three exceptions (23) which resulted in a conclusion that only one (1) Organization reported was truly a subrecipient. This subrecipient was not captured on the SEFA and the elements of monitoring were not in place. The review of the contract agreement between Polk County and this subrecipient did not meet all requirements under 2 CFR section 200.332(a). Cause: The distinction between the entity types receiving this federal funding was not fully understood by personnel. Effect: Recipients and subrecipients are the first line of defense and responsible for ensuring the SLFRF award funds are not used for ineligible purposes, and there is no fraud, waste, or abuse associated with their SLFRF award. The terms and conditions of Federal awards flow down to subawards to subrecipients, requiring subrecipients to comply with all requirements of recipients such as the treatment of eligible uses of funds, procurement, and reporting requirements. A lack of monitoring can lead to noncompliance by the subrecipient which ultimately impacts the compliance of the pass-through entity. Repeat Finding: No. Recommendation: We recommend an amended subrecipient contract that complies with all guidelines under 2 CFR section 200.332(a) be put into place between Polk County and the identified subrecipient. In addition, we recommend a risk assessment of this subrecipient be performed and depending on the results of the assessment, determine a planned schedule of monitoring that matches frequency and intensity that aligns with the risk assessment. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004-Controls Over Reporting Federal Agency: U.S. Department of the Treasury Federal Program Name: Covid-19 Emergency Rental Assistance Assistance Listing Number: 21.023 Federal Award Identification Number: 1505-0266 and 1505-0270 Award Period: September 30, 2021-September 30, 2022, for ERA1 and May 10, 2021 through September 30, 2025 for ERA 2 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: As a condition of receiving federal awards, non-federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to also maintain internal control to provide reasonable assurance of compliance within these requirements. The County management is responsible for establishing and maintaining internal controls over grants. Condition/Context: Auditor selected and tested a statistically valid sample of 5 financial reports and 8 performance reports from the audit period. There was no evidence of review performed on any of the 13 reports. Questioned costs: N/A Cause: During the audit period there was turnover in grant management. Reports that were previously prepared by a knowledgeable member and then reviewed by the HND Manager discontinued to be reviewed after the departure of the HND Manager. There was no assigned replacement for the review process since the original preparer ultimately was promoted into the HND Manager roll. Effect: A lack of review can cause errors to go undetected in the reporting to the grantor. Repeat Finding: No Recommendation: We recommend the County review Government Finance Officers Association's (GFOA) Best Practices for Internal Control for Grants published September 1, 2022, and update internal processes to ensure tasks and review of tasks continue even during periods of staff turnover or vacancies. The County should consider cross-training personnel to allow preparation of certain reports to be prepared and reviewed by separate knowledgeable individuals. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004-Controls Over Reporting Federal Agency: U.S. Department of the Treasury Federal Program Name: Covid-19 Emergency Rental Assistance Assistance Listing Number: 21.023 Federal Award Identification Number: 1505-0266 and 1505-0270 Award Period: September 30, 2021-September 30, 2022, for ERA1 and May 10, 2021 through September 30, 2025 for ERA 2 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: As a condition of receiving federal awards, non-federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to also maintain internal control to provide reasonable assurance of compliance within these requirements. The County management is responsible for establishing and maintaining internal controls over grants. Condition/Context: Auditor selected and tested a statistically valid sample of 5 financial reports and 8 performance reports from the audit period. There was no evidence of review performed on any of the 13 reports. Questioned costs: N/A Cause: During the audit period there was turnover in grant management. Reports that were previously prepared by a knowledgeable member and then reviewed by the HND Manager discontinued to be reviewed after the departure of the HND Manager. There was no assigned replacement for the review process since the original preparer ultimately was promoted into the HND Manager roll. Effect: A lack of review can cause errors to go undetected in the reporting to the grantor. Repeat Finding: No Recommendation: We recommend the County review Government Finance Officers Association's (GFOA) Best Practices for Internal Control for Grants published September 1, 2022, and update internal processes to ensure tasks and review of tasks continue even during periods of staff turnover or vacancies. The County should consider cross-training personnel to allow preparation of certain reports to be prepared and reviewed by separate knowledgeable individuals. Views of responsible officials: There is no disagreement with the audit finding.