CORRECTIVE ACTION PLAN Spartanburg County, South Carolina respectively submits the following corrective action plan for the year ended June 30, 2022: Name and address of independent accounting firm: Halliday, Schwartz & Co. 824 East Main St. Spartanburg, SC 29302 Audit period: June 30, 2022 The find...
CORRECTIVE ACTION PLAN Spartanburg County, South Carolina respectively submits the following corrective action plan for the year ended June 30, 2022: Name and address of independent accounting firm: Halliday, Schwartz & Co. 824 East Main St. Spartanburg, SC 29302 Audit period: June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section III: Federal Awards Findings Finding 2022-001: US Department of Treasury Emergency Rental Assistance Program CFDA Number: 21.023 Grant Award Number : Multiple Awards Compliance Requirement: Allowable Costs Type of Finding: Significant deficiency in internal control over compliance Criteria: In the US Department of Treasury Reporting Guidance - Emergency Rental Assistance Program, page 34, it requires recipients to provide a current performance narrative of 2,000 words or less describing the performance and accomplishments of the subject ERA project over the reporting period (which is quarterly). The narrative must include the following information: ? Activities implemented and notable achievements over the calendar quarter ? Activities planned for next quarter ? Notable challenges and status of each challenge ? Details on compliance/non-compliance issues and mitigation plans ? Requests for additional assistance or guidance from Treasury ? Other information, as appropriate. Condition: While the County complied with all other aspects of reporting for the program, the County did not comply with the performance reporting requirement noted above. This section of the quarterly reports submitted to Treasury were marked "N/A", and therefore lacked the required elements as listed above. Questioned Costs: None Context: As this is a new federal program (this is the second reporting year), the guidance from Treasury changed often. We observed that efforts were made to comply with reporting requirements, and this appeared to be an oversight. The quarterly reports were accepted by Treasury, with no further follow-up from them. Effect or Potential Effect: The effect of the noncompliance noted above is that it increases risk for action by the federal agency for contract noncompliance. Cause: Misunderstanding of grant contract performance reporting requirement. Recommendation: We recommend that the responsible report preparer create a template with the required reporting elements for the narrative portion. Each quarter the template can be updated with the appropriate wording, as required. In the User Guide - Treasury's Portal for Recipient Reporting, page 54, it suggests typing the information directly on screen or upload a document via the "upload fi les" functionality on the website. We recommend this process begin with the first quarterly report filed in 2023, since all previously filed reports were accepted online and cannot be changed. Planned Implementation Date of Corrective Action: January, 2023 Person Responsible for Corrective Action: Kathy Rivers, Director of Community Development