Finding caption:
The Authority did not have adequate internal controls for ensuring
compliance with federal maintenance of effort requirements.
Name, address, and telephone of Authority contact person:
Rina Yu, Senior Accountant
20811 84th Avenue South, Suite 110
Kent WA 98032
253-856-4303
Correct...
Finding caption:
The Authority did not have adequate internal controls for ensuring
compliance with federal maintenance of effort requirements.
Name, address, and telephone of Authority contact person:
Rina Yu, Senior Accountant
20811 84th Avenue South, Suite 110
Kent WA 98032
253-856-4303
Corrective action the auditee plans to take in response to the finding:
General Response:
Puget Sound Fire respectfully disagrees with the Auditor's decision to elevate the two issues identified below to the level of a finding. Puget Sound Fire believes it substantially complied with the MOE and other grant requirements identified in issue 1 and worked closely with the
granting agency, FEMA, to comply with all grant requirements. Based on the specific responses below, and Puget Sound Fire's good faith and reasonable efforts to cooperate and comply with the grant requirements, we respectfully request that the items be addressed in a
management letter rather than a finding.
Issue 1: Maintenance of Effort
Puget Sound Fire respectfully disagrees with the Auditor's proposed finding. Puget Sound Fire did maintain and document the Maintenance of Effort attestation as described in the AFG grant's Notice of Funding Opportunity and followed best practices for tracking fiscal budget information as previously prescribed by SAO personnel. Puget Sound Fire's compliance is demonstrated in the 3-year budget history within the grant application/contract itself and Puget Sound Fi re provided SAO support Maintenance of Effort calculations for the years the grant was awarded. Puget Sound Fire Puget Sound Fire's governing board also approved budget increases year over year for the duration of the grant that exceeded the 80% average requirement. There is no 2 CFR Part 200 guidance on MOE other than what is included in the NOFO, and as an attestation, and the 3-year budget history was acceptable by FEMA, the
grantor.
Additionally, a finding is not warranted as following receipt of the same finding for the 2021 audit Puget Sound Fire adopted the SA O's feedback and has been following that guidance since then. Basing a finding for the current audit for actions that have been corrected pursuant to a prior audit is unreasonable. Puget Sound Fire complied with the MOE requirements following the 2021 finding and has no ability to go back to 2021 and change the past.
Puget Sound Fire also notes that Puget Sound Fire's MOE efforts were reviewed, approved and monitored by FEMA, the grantor without issue. Puget Sound Fire has worked with and will continue to work with the grantor moving forward to implement best practices in calculating and maintaining MOE.
AFG NOFO Statement - Maintenance of Effort
A maintenance of effort is required under this program for all recipients, unless modified by a waiver, subject to waiver eligibility.An applicant seeking an award under this NOFO shall agree to maintain during the term of the grant, the applicant's aggregate expenditures relating to the activities allowable under this NOFO at not less than 80 percent of the average amount of such expenditures in the two fiscal years preceding the fiscal year in which the grant award is received. For more information on waiver eligibility, please see Appendix C-Award
Administration Information, Section I. Economic Hardship Waivers of Cost Share and Maintenance of Effort Requirements for the FP&S Grant Program for more information.
Anticipated date to complete the corrective action:
Puget Sound Fire thanks the Washington State Auditor's Office for its thorough review of fiscal years 2021 through 2023. We are committed to implementing the recommended corrective actions, enhancing our internal controls, and addressing all identified deficiencies. Corrective
actions for the three issues identified by the SAO have been initiated and will be fully implemented by January 1, 2026.
Issue 1: Maintenance of Effort (MOE)
Puget Sound Fire currently maintains and documents the MOE attestation in accordance with applicable Federal Notices of Funding Opportunities. To further improve compliance, we will work directly with our grantors to ensure MOE calculations align with best practices and updated guidance. This action will be completed by January 1, 2026.