2024-006 – Reporting – Internal Control and Compliance over Reporting City’s Corrective Action Plan: This finding is related to COVID-19 funding that was administered during the height of the pandemic, when multiple funding sources were required to be expended simultaneously. Section 15011 reporting...
2024-006 – Reporting – Internal Control and Compliance over Reporting City’s Corrective Action Plan: This finding is related to COVID-19 funding that was administered during the height of the pandemic, when multiple funding sources were required to be expended simultaneously. Section 15011 reporting was a new requirement within the CARES Act of 2020, to the Department and the City at that time. By the time this issue was identified as an area of deficiency in the prior audit period, it was no longer possible to retroactively correct or report for that respective audit year, nor for the current audit period. In response to the prior audit report, the City evaluated options to centralize Section 15011 reporting, given that it falls under the Federal Funding Accountability and Transparency Act (FFATA) of 2006 and is closely tied to procurement activities of over $150,000. The City explored whether this reporting could be managed through the City’s Grant Manager position under the Administrative Services Department (ASD) The City accepts the finding of noncompliance with WIFIA reporting requirements, as the Annual Comprehensive Financial Report (ACFR) for the year ended June 30, 2024 was dated September 17, 2025, which exceeded the required 180-day submission deadline of December 27, 2024. The delay was due to challenges in completing the City-wide ACFR resulting from ongoing staff turnover. As a corrective action, the City will strengthen internal processes and oversight to ensure the ACFR is completed and submitted in a timely manner in future reporting periods. The City will implement enhanced internal controls to ensure timely, accurate, and complete submission of Quarterly Project and Expenditure (P&E) Reports for both SLFRF and ARPA Revenue Loss. Corrective actions include establishing a formal internal reporting calendar with assigned responsibilities to meet Treasury deadlines, performing a documented quarterly reconciliation of general ledger obligations and expenditures to P&E report amounts, correcting prior reporting errors or duplications, and requiring supervisory review and approval of all reports before submission to the U.S. Department of the Treasury. Additionally, the City will develop standardized reporting templates, provide staff training on Treasury reporting requirements, and maintain oversight by the Finance Director to ensure ongoing compliance, accuracy, and timely reporting of all expenditures. Responsible Person: Grants Manager; Accounting Manager, CFO and Departments Administering Grants Expected Implementation Date: FY 2026