FAC Explorer

Finding 1115515 (2024-012)

Significant Deficiency Repeat Finding
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-03-28
Audit: 349776
Organization: City of Boston (MA)
Auditor: Kpmg LLP

AI Summary

  • Core Issue: The Boston Fire Department lacks effective internal controls over financial and performance reporting, leading to late submissions and unverified approvals.
  • Impacted Requirements: Failure to comply with DHS and FEMA reporting deadlines for the SF-425 and PPRs, risking non-compliance with federal regulations.
  • Recommended Follow-Up: Implement formal review processes for SF-425 approvals and establish timely filing procedures for PPRs to ensure accuracy and compliance.

Finding Text

Finding number: 2024-012 Federal agency: U.S. Department of Homeland Security Pass-through agency: N/A – Direct Funding Program: Staffing for Adequate Fire and Emergency Response (SAFER) ALN #: 97.083 Award number: EMW-2020-FF-00996 Award year: February 27, 2022 to February 26, 2025 Finding: Internal Control over Financial Reporting and Performance Reporting Prior Year Finding: Yes; 2023-015 and 2023-016 Type of Finding: Significant Deficiency Criteria Financial Reporting Per the Department of Homeland Security (DHS) Notice of Funding Opportunity (NOFO) for Fiscal Year 2020 Staffing for Adequate Fire and Emergency Response (SAFER) Grant Program, recipients of the SAFER Program grants are required to submit an FFR (SF-425) on a semi-annual basis. The FFR is to be submitted using the online FEMA GO based on the calendar year beginning with the period after the start of the period of performance. Grant recipients are required to submit an FFR throughout the entire period of performance of the grant. Reports are due: 1. No later than July 30 (for the period January 1 – June 30) 2. No later than January 30 (for the period July 1 – December 31) 3. Within 120 days after the end of the period of performance Performance Reporting Per the Department of Homeland Security (DHS) Notice of Funding Opportunity (NOFO) for Fiscal Year 2020 Staffing for Adequate Fire and Emergency Response (SAFER) Grant Program and the Federal Emergency Management Agency (FEMA) Grant Programs Directorate Information Bulletin No. 471, the recipient is responsible for completing and submitting a Programmatic Performance Report (PPR) using FEMA GO. For those awards which began in prior year, the PPR is due every six months based on the calendar year until the period of performance ends, and no later than 30 days after the six-month period end.Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards 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. Condition Financial Reporting During our testing of both semi-annual Federal Financial SF-425 (SF-425) reports, we were unable to verify approval of the SF-425 for reporting period ending 12/31/2023 by the Deputy Commissioner of the Boston Fire Department prior to submission. Performance Reporting Additionally, during our testing over both required semi-annual performance progress reports (PPRs) for fiscal year 2023, we noted the semi-annual PPR covering July 1, 2023 to December 31, 2023 was filed 65 days late on April 5, 2024. Additionally, we noted the semi-annual PPR covering January 1, 2024 to June 30, 2024 was filed one day late on August 1, 2024. Cause Financial Reporting This appears to be due to lack of a formal documented review over the semi-annual SF-425 reports. Progress Reporting This appears to be due to inadequate program detail to ensure complete and accurate information for reporting at the time of the submission deadlines. Effect Financial Reporting The Boston Fire Department (BFD) does not have effective internal controls over the Federal award to ensure the completeness and accuracy of the semi-annual SF-425 Financial Report. Performance Reporting The BFD has an insufficient process in place to ensure completeness and accuracy of the period expenditures and the timely filing of the semi-annual PPRs. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs NoneRecommendation We recommend that the BFD re-enforce control procedures to ensure that the SF-425 Financial Reports formal review and approval is documented. Additionally, we recommend that the BPD implement control procedures to ensure that the PPRs are filed timely and reviewed against supporting schedules to ensure completeness and accuracy of each report prior to submission. View of Responsible Officials from the Auditee BFD has taken considerable steps to incorporate and implement proper control procedures surrounding all grant related matters, i.e. programmatic and financial reporting and oversight. In August 2023, the department hired a Financial Grants Manager with more than ten years of experience working in municipal government with grants to ensure proper financial oversight is established and enforced. In February 2024, the department hired a Programmatic Grants Manager to ensure and implement proper policies and procedures regarding programmatic aspects of the department’s external funds. The department has acquired licenses for Airtable, an online platform for creating and sharing relational databases. It combines the features of a database and a spreadsheet, allowing users to store, organize, and collaborate on information about anything. This platform allows the department to track upcoming reporting deadlines, maintain information regarding grant related purchases, etc. The Programmatic and Financial Grants Manager have been reviewing all currently funded grants, to include SAFER, to ensure that the general ledger postings accurately reflect allowable costs so that when reports are filed the information reported in FEMA GO is accurate and complete. The Department projected that timely and accurate filing will be in effect no later than in January 2025 in order to complete the semi-annual reports due for the period ending December 31, 2024. The department had a high success rate in ensuring timely completion, approval and submission of financial reports for the most recently reporting period.

Categories

Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 539061 2024-003
    Significant Deficiency Repeat
  • 539062 2024-004
    Significant Deficiency
  • 539063 2024-005
    Significant Deficiency
  • 539064 2024-006
    Significant Deficiency Repeat
  • 539065 2024-007
    Significant Deficiency Repeat
  • 539066 2024-008
    Significant Deficiency Repeat
  • 539067 2024-009
    Significant Deficiency Repeat
  • 539068 2024-009
    Significant Deficiency Repeat
  • 539069 2024-009
    Significant Deficiency Repeat
  • 539070 2024-010
    Significant Deficiency Repeat
  • 539071 2024-010
    Significant Deficiency Repeat
  • 539072 2024-011
    Material Weakness
  • 539073 2024-012
    Significant Deficiency Repeat
  • 1115503 2024-003
    Significant Deficiency Repeat
  • 1115504 2024-004
    Significant Deficiency
  • 1115505 2024-005
    Significant Deficiency
  • 1115506 2024-006
    Significant Deficiency Repeat
  • 1115507 2024-007
    Significant Deficiency Repeat
  • 1115508 2024-008
    Significant Deficiency Repeat
  • 1115509 2024-009
    Significant Deficiency Repeat
  • 1115510 2024-009
    Significant Deficiency Repeat
  • 1115511 2024-009
    Significant Deficiency Repeat
  • 1115512 2024-010
    Significant Deficiency Repeat
  • 1115513 2024-010
    Significant Deficiency Repeat
  • 1115514 2024-011
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $203.78M
84.010 Title I Grants to Local Educational Agencies $58.87M
14.267 Continuum of Care Program $40.38M
10.555 National School Lunch Program $30.91M
84.027 Special Education Grants to States $17.94M
97.067 Homeland Security Grant Program $13.81M
97.083 Staffing for Adequate Fire and Emergency Response (safer) $9.97M
14.239 Home Investment Partnerships Program $5.87M
21.023 Emergency Rental Assistance Program $4.73M
84.173 Special Education Preschool Grants $3.24M
84.424 Student Support and Academic Enrichment Program $3.12M
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $3.00M
14.231 Emergency Solutions Grant Program $2.77M
84.048 Career and Technical Education -- Basic Grants to States $2.24M
84.365 English Language Acquisition State Grants $1.94M
10.558 Child and Adult Care Food Program $1.93M
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $1.89M
66.443 Reducing Lead in Drinking Water (sdwa 1459b) $1.48M
97.106 Securing the Cities Program $1.28M
14.905 Lead Hazard Reduction Demonstration Grant Program $1.11M
10.582 Fresh Fruit and Vegetable Program $1.09M
14.248 Community Development Block Grants Section 108 Loan Guarantees $919,562
10.559 Summer Food Service Program for Children $883,164
20.500 Federal Transit Capital Investment Grants $815,500
16.833 National Sexual Assault Kit Initiative $777,046
84.287 Twenty-First Century Community Learning Centers $748,658
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $737,136
84.184 School Safely National Activities $731,838
97.111 Regional Catastrophic Preparedness Grant Program (rcpgp) $711,470
93.493 Congressional Directives $680,072
93.053 Nutrition Services Incentive Program $593,356
97.024 Emergency Food and Shelter National Board Program $556,657
93.079 Cooperative Agreements to Promote Adolescent Health Through School-Based Hiv/std Prevention and School-Based Surveillance $526,196
20.616 National Priority Safety Programs $496,691
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $425,792
93.043 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $402,254
93.052 National Family Caregiver Support, Title Iii, Part E $398,440
97.044 Assistance to Firefighters Grant $393,945
21.027 Coronavirus State and Local Fiscal Recovery Funds $353,549
94.016 Americorps Seniors Senior Companion Program (scp) 94.016 $329,650
16.738 Edward Byrne Memorial Justice Assistance Grant Program $302,301
20.219 Recreational Trails Program $300,000
97.047 Bric: Building Resilient Infrastructure and Communities $294,366
84.002 Adult Education - Basic Grants to States $276,923
16.741 Dna Backlog Reduction Program $254,896
84.336 Teacher Quality Partnership Grants $222,942
16.015 Missing Alzheimer's Disease Patient Assistance Program $142,079
94.002 Americorps Seniors Retired and Senior Volunteer Program (rsvp) 94.002 $134,183
10.935 Urban Agriculture and Innovative Production $132,138
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $131,056
14.401 Fair Housing Assistance Program $119,749
84.196 Education for Homeless Children and Youth $106,059
16.588 Violence Against Women Formula Grants $104,318
14.241 Housing Opportunities for Persons with Aids $99,539
45.301 Museums for America $93,526
97.042 Emergency Management Performance Grants $91,427
32.001 Communications Information and Assistance and Investigation of Complaints $77,625
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $73,828
16.838 Comprehensive Opioid, Stimulant, and Other Substances Use Program $68,165
10.331 Gus Schumacher Nutrition Incentive Program $65,759
14.889 Choice Neighborhoods Implementation Grants $59,681
10.579 Child Nutrition Discretionary Grants Limited Availability $59,354
97.056 Port Security Grant Program $42,469
10.575 Farm to School Grant Program $37,410
93.042 Special Programs for the Aging, Title Vii, Chapter 2, Long Term Care Ombudsman Services for Older Individuals $35,915
14.246 Community Development Block Grants/brownfields Economic Development Initiative $28,049
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $27,991
66.818 Brownfields Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Cooperative Agreements $25,980
15.904 Historic Preservation Fund Grants-in-Aid $11,270
16.710 Public Safety Partnership and Community Policing Grants $10,945
16.820 Postconviction Testing of Dna Evidence $9,290
14.218 Community Development Block Grants/entitlement Grants $2,146
14.261 National Homeless Data Analysis Project (nhdap) $1,750
10.727 Inflation Reduction Act Urban & Community Forestry Program $1,232
17.259 Wioa Youth Activities $1,145
11.307 Economic Adjustment Assistance $949
17.285 Registered Apprenticeship $582
17.258 Wioa Adult Program $214
21.009 Volunteer Income Tax Assistance (vita) Matching Grant Program $182
17.289 Community Project Funding/congressionally Directed Spending $107
17.278 Wioa Dislocated Worker Formula Grants $101
17.207 Employment Service/wagner-Peyser Funded Activities $67