Finding 1105634 (2023-002)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2025-03-20
Audit: 347168
Organization: City of Cupertino (CA)

AI Summary

  • Core Issue: The City lacked proper segregation of duties in preparing and submitting reports related to the American Rescue Plan Act, leading to incorrect reporting.
  • Impacted Requirements: Non-compliance with 2 CFR 200.303(a) and SLRF requirements for timely fund obligation and accurate reporting.
  • Recommended Follow-Up: Strengthen report submission processes and conduct staff training on grant compliance to prevent future issues.

Finding Text

2023-002 - Reporting – Internal Control and Compliance over Reporting (Material Weakness) Identification of the Federal Programs: Assistance Listing Number: 21.027 Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Federal Agency: Department of Treasury Pass-Through Entity: N/A Federal Award Number and Award Year: 1505-0271 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to 2 CFR 200.303(a), the non-federal entity must 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). These would include segregation of duties over report preparation and submission to ensure compliance with deadline requirements. Further, per State and Local Fiscal Recovery Funds (“SLRF”) requirements, the recipients are also required to obligate funds incurred related to revenue replacement under “provision of government services” sub-expenditure category. Condition: The City did not have proper segregation of duties in place for the preparation, approval and submission of the American Rescue Plan Act (“ARPA”) -related reportorial requirements to the U.S. Department of Treasury. Further, the audit team noted that the City did not properly obligate the funds related to revenue replacement category on its annual project and expenditures report resulting to incorrect reporting. Subsequently, the City corrected the obligation of funds during the March 2024 annual reporting. Cause: There was no policy and procedure in place to enhance the internal control over the report submission. In addition, the City was not familiar with the obligation requirement. Effect or Potential Effect: Failure to implement proper segregation of duties, and failure to report correct expended amounts under provision of government services in the annual report resulted in non liance requirements. Not obligating the fund timely could potentially lose the funding. Questioned Costs: None. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: Yes. See prior year finding 2022-001. Recommendation: We recommend that the City strengthen their report submission process and procedures to ensure all required reports are properly reviewed and approved and submitted. Further, we recommend the City to have in depth staff training with regard to the grant compliance requirements in order to avoid misinterpretation of the necessary requirements. Views of Responsible Officials: Management concurs the finding.

Categories

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 529192 2023-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $6.10M
14.218 Community Development Block Grants/entitlement Grants $196,616
20.205 Highway Planning and Construction $182,297
93.008 Medical Reserve Corps Small Grant Program $18,677