2024-010 Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Federal Financial Assistance Listing Number: 97.036
Federal Grantor: U.S. Department of Homeland Security
Pass Through: California Office of Emergency Services
Award No. and Year: 059-00000 and 2019
Compliance ...
2024-010 Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Federal Financial Assistance Listing Number: 97.036
Federal Grantor: U.S. Department of Homeland Security
Pass Through: California Office of Emergency Services
Award No. and Year: 059-00000 and 2019
Compliance Requirements: Reporting
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition:
For two (2) out of three (3) project application summary reports tested, the OCPW did not retain evidence to document the individual who reviewed and approved the required reports.
Cause:
The department’s procedures did not include documenting the review and approval of the reports prior to submission.
Effect:
Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
A non-statistical sample of three (3) of nine (9) Grant Project Application Summary Reports were
selecting for testing. The condition above was identified during our procedures over reporting testing.
Repeat Finding:
No.
Recommendation:
We recommend the OCPW department revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission.
Management Response and Corrective Action:
1. Person Responsible:
• FEMA Public Assistance Grants Coordinator – Responsible for completing reports, uploading documents to the FEMA Grants Portal, and ensuring accurate records.
• OCPW Emergency Manager Responsible for reviewing, approving, and submitting project applications.
2. Corrective Action Plan:
• Revised Procedures for Review and Approval:
i. The FEMA Public Assistance Grants Coordinator will be responsible for completing the Project Application Summary Reports.
ii. Upon completion, the Grants Coordinator will upload all supporting documents into the FEMA Grants Portal. The system automatically timestamps each document and records the name of the individual who uploaded it, ensuring clear documentation of the review process.
iii. After all required documents are uploaded, the OCPW Emergency Manager will be notified that the project application is ready for review.
iv. The OCPW Emergency Manager will then:
1. Review the submitted documents in the FEMA Grants Portal.
2. Confirm that the reported costs align with the information provided by the reporting County agency.
3. Approve and submit the project application to Cal OES and FEMA for project approval.
• Retention of Documentation:
i. The FEMA Grants Portal serves as the official system of record, ensuring all uploaded documents are timestamped and traceable.
ii. All project application approvals, cost documentation, and required forms will be retained electronically within the system for audit and compliance purposes.
• Training and Implementation:
i. Staff responsible for grant reporting will receive training on the revised process, including proper document upload procedures and compliance expectations.
ii. The updated process will be implemented immediately.
• Monitoring and Compliance:
i. The OCPW Emergency Manager will conduct semiannual internal reviews of project applications to ensure compliance with the updated procedures.
ii. Any issues identified during internal reviews will be addressed through additional staff training and process improvements.
3. Anticipated Implementation date: Immediate, March 18, 2025
• Staff Training: Within 30 days
• Semiannual Compliance Review: Beginning next quarter
i. First review will take place May 1, 2025. Followed by another review in October 2025.