2025-004 Per 2 CFR §200.510(b), the SEFA must include: - A list of individual federal programs by agency, including the Assistance Listing number. - The total federal awards expended for each program, including capital projects funded by federal grants. - Amounts passed through to subrecipients. - O...
2025-004 Per 2 CFR §200.510(b), the SEFA must include: - A list of individual federal programs by agency, including the Assistance Listing number. - The total federal awards expended for each program, including capital projects funded by federal grants. - Amounts passed through to subrecipients. - Outstanding balances for loan or loan guarantee programs. - Significant accounting policies used in preparing the SEFA. Recommendation: We recommend that management: - Implement a reconciliation process to ensure that all federal expenditures are accurately captured in the SEFA. - Provide additional training for accounting personnel on federal reporting requirements. - Review all local government awards to determine whether Federal funds are a component of the contracts. - Review SEFA data for completeness and accuracy before submission. Management’s Response: Management concurs with the recommendation. HTM recognizes that accurate SEFA preparation begins with identification of federal funding when an award is received and cannot depend solely on a year-end exercise performed after transactions have already been recorded. Management will establish a federal award identification and reconciliation process connecting contract administration, accounting records, federal award information, and the final SEFA. Corrective Action Status and Plan: Management is reviewing the FY 2025 SEFA and related award information and plans to formalize an enhanced SEFA preparation and review process by December 31, 2026. Finance/Accounting will maintain a centralized award inventory identifying the awarding agency and pass-through entity, Assistance Listing number, period of performance, federal and nonfederal funding components, amounts passed through to subrecipients, outstanding loan or loan-guarantee balances when applicable, and the accounting policies used to prepare the SEFA. At least quarterly, Accounting will reconcile the inventory and cumulative federal expenditures to the general ledger, grant billing records, award agreements, and supporting schedules; differences will be investigated, resolved, and documented. Management also plans to complete a preliminary year-to-date SEFA review before year-end. As part of the immediate FY 2025 remediation, management will document the bridge from the prior SEFA to the final revised schedule; retain support for the funding classification of County Operating and Measure H amounts; reconcile the final SEFA to the general ledger and project schedules; and ensure related amounts and disclosures in the audit report are updated consistently. The additional implementation activities are described below. • Reviewing all new grant agreements and contracts to identify funding sources and determine the appropriate federal participation percentage. • Providing targeted training to accounting personnel regarding federal reporting requirements and awards with blended funding sources. • Establishing a secondary management review of the SEFA, including reconciliation of expenditures to underlying award agreements and supporting schedules. The Mission's procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) did not adequately address contracts containing multiple funding sources. In certain instances, awards administered through local government entities contained both federal and state funding components; however, the agreements were initially classified as fully federal for SEFA reporting purposes. In addition, no formal process existed to systematically review funding agreements and document the federal funding portion of each award prior to SEFA preparation. The enhanced review and monitoring procedures will improve the accuracy and completeness of SEFA reporting, ensure that expenditures are properly classified between federal and non-federal funding sources, and reduce the risk of future reporting errors and noncompliance with Uniform Guidance requirements. Name of responsible person: Tisha Lazare, Chief Financial Officer Anticipated completion date: December 31, 2026