Finding 1076238 (2023-001)

Finding 2023-001 Significant Deficiency: Reporting Compliance and Control Finding ALN 14.537 - Eviction Protection Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: N/A Criteria Or Specific Requirement: 2 CFR Part 170 requires direct recipients of grants to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) no later than the last day of the month following the month in which the agreement was made. Additionally, proper controls must be in place surrounding review and approval of the report prior to submission to FSRS. Condition: Audit procedures revealed that the FFATA reports were not properly or timely submitted. Cause: Management was not aware FFATA reports were an applicable requirement of the federal program. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Reports for subrecipients who were awarded over $30,000 in federal funding were not compiled, reviewed or submitted by last day of the month following the month in which the agreement was made. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management compile and submit FFATA report timely for all subrecipient agreements for greater than $30,000 in federal funding with proper review and approval prior to submission. Views Of Responsible Officials: All necessary FFATA will be filed within 30 days. Legal Services of Eastern Missouri (LSEM) will develop policies and procedures within 60 days to ensure that all FFATA reports are submitted in a timely manner. LSEM will provide training regarding all grant compliance for all staff involved in grant management and compliance within 90 days.