Finding Text
Reporting – U.S. Department of Housing and Urban Development - CDBG Program (AL
#14.218)
Criteria: Internal controls should be in place to ensure that reporting requirements are met as specified in the guidance provided by both the granting agency, as well as federal codifications. 2 CFR Part 170 guidance specifies that direct recipients are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Condition and Context: During testing of reporting requirements during the 2023 fiscal year it was noted the City, as a direct recipient of U.S Department of Housing and Urban Development awards, was not timely filing subawards through the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). During the City’s fiscal year 2024, the City expended 3 subawards of $30,000 which in total amount to $138,882. Of the 3 subawards, 2 of the 3 were not reported timely in the FSRS.
Cause: Per review of the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS), the City’s CDBG Program had obligations of programs award B-23-MC-47-0002 were not timely filed for 2 of the 3 subawards. However, they were ultimately filed late under the Federal Funding Accountability and Transparency Act. This was due to oversight by the program management for the CDBG program.
Effects: The City was not in compliance with the reporting requirements.
Questioned Costs: None.
Recommendation: We recommend the City take necessary steps in the future to ensure that those responsible for the program are aware of reporting requirements and have a process in place to ensure that all reports and submissions are completed and submitted timely. We recommend that the City implement the following in order to prevent recurrence:
1. Formalize Policies: Establish written procedures for FFATA reporting.
2. Assign Responsibility: Designate a staff member to track and submit reports.
3. Implement a Reporting Tracker: Maintain a sub-recipient reporting log with due dates.
4. Review Process: Institute a review process to ensure all sub-awards greater than
$30,000 are reported timely.
5. Periodic Monitoring: Conduct quarterly reviews of FFATA compliance.
Auditee’s Response: We concur with the finding. Due to changes in departmental management and responsibilities submission was not timely. We have now implemented policies and procedures to ensure grant activity is reported in accordance with the grant requirements.