Finding Type - Material weakness and material noncompliance with laws and regulations Condition ? The Authority disbursed a portion of its CARES Act funds to community partners; however, many of those partners offer only Section 5310 service for seniors and individuals with disabilities. Section 531...
Finding Type - Material weakness and material noncompliance with laws and regulations Condition ? The Authority disbursed a portion of its CARES Act funds to community partners; however, many of those partners offer only Section 5310 service for seniors and individuals with disabilities. Section 5310 program expenses are not allowable under the CARES Act. Identification of How Questioned Costs Were Computed ? Questioned costs represent the total amount of CARES Act funds passed through to community partners. Context - During the fiscal year, SMART passed through $1,146,291 to 35 community partners. Cause and Effect - The CARES Act award was new to SMART in fiscal year 2020. SMART's other federal awards have existed for many years and SMART is very familiar with their requirements and allowable uses. SMART sought to share the new award with its community partners but was not aware that most of them did not have expenditures allowable under the CARES Act until the matter was identified during SMART's most recent triennial review. Recommendation - When new awards are received, we recommend SMART thoroughly analyze the compliance requirements, including the allowable uses. Views of Responsible Officials and Corrective Action Plan ? SMART management is aware of the issue and has been diligently working with our FTA regional office to correct the issue. While certain community partner expenses were not eligible under CARES, they are certainly eligible under CRRSA and ARPA funding grants. We are in the process of finalizing a plan, with the FTA, where all community partner relief funding will be reprogramed under the CRRSA and ARPA grants. This correction plan, once finalized, will result in no reduction of federal relief funding to SMART or any of our community partners. Given extraordinary circumstances and expedited nature of the CARES funding, we do not believe that this issue will be a significant risk for future grant funding, however SMART has modified our grant policy manual to ensure a more thorough review of eligible expenses for subrecipients. Contact person responsible for corrective action: Ryan Byrne, CFO Anticipated Completion Date: 12/31/2022