Finding 2024-007: Reporting – Significant Deficiency over Internal Control over Reporting
Assistance Listing
Program: Coronavirus State and Local Fiscal Recovery Fund
Finding:
Per 2 CFR 200.303, recipients are required to establish, document, and maintain effective internal controls that provide...
Finding 2024-007: Reporting – Significant Deficiency over Internal Control over Reporting
Assistance Listing
Program: Coronavirus State and Local Fiscal Recovery Fund
Finding:
Per 2 CFR 200.303, recipients are required to establish, document, and maintain effective internal controls that provide reasonable assurance of compliance with Federal statutes, regulations, and award terms. These controls should align with GAO's Standards for Internal Control in the Federal Government and COSO's Internal Control – Integrated Framework.
Condition:
The City did not maintain documentation supporting the internal control process over the submission of required quarterly reports during fiscal year 2024.
Corrective Actions Taken:
1. Establishment of Formal Reporting Controls: The City has developed and implemented a standardized procedure for the preparation, review, and submission of all quarterly reports related to federal awards, including a designated checklist and approval workflow to ensure compliance with reporting deadlines and content accuracy.
2. Documentation and Retention Protocols: All steps in the reporting process are now formally documented, including preparer and reviewer signoffs. Supporting documentation is retained in a centralized location accessible to relevant staff and auditors for verification purposes.
3. Internal Review and Oversight: The Office of Management, Policy, and Grants has assigned responsibility to the Grant Management Team for conducting secondary reviews of quarterly report submissions. This includes validating that internal controls have been followed, and evidence of compliance is documented.
4. Staff Training: Staff involved in federal reporting have received training on the internal control requirements outlined in 2 CFR 200.303, COSO, and GAO Green Book standards to reinforce the importance of documentation and control procedures.
5. Monitoring and Compliance Checks: A quarterly compliance checklist and review process have been instituted to ensure ongoing adherence to federal internal control requirements. Noncompliance will be flagged and reviewed with senior leadership.
Contact: Shannon McCue, Director of Management, Policy, and Grant Anticipated Completion Date: January 2026