Finding 1081163 (2022-004)

Federal Program Information Federal Agencies: United States Department of Homeland Security Awards: Assistance Listing Number 97.036 – COVID-19 – Disaster Grants - Public Assistance (Presidentially Declared Disasters) Award Periods: January 20, 2020 – May 11, 2023 Description: Preparation of Schedule of Expenditures of Federal Awards Type of Finding: Material Weakness in Internal Control Over Compliance Criteria The Uniform Guidance 2 CFR section 200.303 states, “The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare the Schedule for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.” Condition The System omitted the obligated expenditures related to the Assistance Listing Number 97.036 – COVID-19 – Disaster Grants - Public Assistance (Presidentially Declared Disasters) (“FEMA”) in the Schedule. Cause The System misinterpreted the FEMA Public Assistance Grant Program guidance for reporting Assistance Listing 97.036 expenditures in the Schedule, which is based on when (1) FEMA has approved (i.e., obligated) the non-federal entity’s project worksheet (PW), and (2) the non-federal entity has incurred the eligible expenditures. The System interpreted the date the PW is approved (i.e., obligated) as the date the Virginia Department of Emergency Management will authorize disbursement and appropriate of the funds from the Department of Planning and Budget rather than the date FEMA obligated the PW. Effect or potential effect The Schedule prepared by the System was misstated but was subsequently corrected. A misstated Schedule could result in the improper selection of federal award major programs or an incorrect percentage of coverage being calculated resulting in a restatement of a previously issued Uniform Guidance report. Questioned costs None. Identification of a repeat finding This is not a repeat finding. Context Expenditures for Assistance Listing 97.036 of $31,631,420 were excluded from the Schedule. These expenditures related to PWs obligated in 2022 and expenditures incurred in previous fiscal years and consequently should have been recorded in the 2022 Schedule. Recommendation The System should update its policies and procedures and internal controls, specifically the process to accumulate and report FEMA expenditures of federal awards to be in accordance with the FEMA Schedule requirements outlined above. View of responsible officials The System agrees with the comment and has developed a plan to correct the finding.