Finding Text
Finding 2023-014 – Noncompliance with Reporting Requirements Over Federal Grant – Coronavirus State
and Local Fiscal Recovery Funds (Repeat Finding – 2022-014)
PASS-THROUGH GRANTOR: Direct Grant
FEDERAL AGENCY: U.S. Department of Treasury
ASSISTANCE LISTING: 21.027
FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds
FEDERAL AWARD YEAR: 2021
CONTROL CATEGORY: Reporting
QUESTIONED COSTS: $0
Condition: In the review of fifty-five (55) expenditures for federal programs, five (5) instances
were noted where the expenditures were not correctly reported on the Coronavirus State and Local
Fiscal Recovery Funds compliance reports.
Cause of Condition: Policies and procedures have not been designed and implemented to ensure
federal expenditures are properly reported in accordance with federal compliance requirements.
Effect of Condition: This condition could result in noncompliance to grant requirements.
Recommendation: OSAI recommends the County gain an understanding of the requirements for this
program and implement internal controls to ensure compliance with these requirements.
Management Response:
Chairman of the Board of County Commissioners: The Board of County Commissioners will take measures
to ensure future compliance with all requirements of federal grants.
Criteria: Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds (10. Reporting.)
reads as follows:
10. Reporting. All recipients of federal funds must complete financial, performance, and compliance
reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a
cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting
must be consistent with the definition of expenditures
pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with
appropriate accounting standards and principles.
In addition, where appropriate, your organization needs to establish controls to ensure completion
and timely submission of all mandatory performance and/or compliance reporting. See Part 2 of this
guidance for a full overview of recipient reporting responsibilities.
Further, 2 CFR § 200.329 Monitoring and Reporting Program Performance (c)(1) reads as follows: The
non-Federal entity must submit performance reports at the interval required by the Federal awarding
agency or pass-through entity to best inform improvements in program outcomes and productivity.
Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual
circumstances, for example where more frequent reporting is necessary for the effective monitoring
of the Federal award or could significantly affect program outcomes. Reports submitted annually by
the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after
the reporting period. Reports submitted quarterly or semiannually must be due no later than 30
calendar days after the reporting period. Alternatively, the Federal awarding agency or
pass-through entity may require annual reports before the anniversary dates of multiple year
Federal awards. The final performance report submitted by the non-Federal entity and/or
pass-through entity must be due no later than 120 calendar days after the period of performance end
date. A subrecipient must submit to the pass-through entity, no later than 90 calendar days after
the period of performance end date, all final performance reports as required by the terms and
conditions of the Federal award. See also § 200.344. If a justified request is submitted by a
non-Federal entity, the Federal agency may extend the due date
for any performance report.