FAC Explorer

Finding 1136479 (2024-103)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-05-09
Audit: 355953
Organization: Pima County (AZ)
Auditor: Arizona Auditor General

AI Summary

  • Core Issue: The County's Grants Management and Innovation Department failed to establish proper internal controls for monitoring compliance with federal reporting requirements for two programs.
  • Impacted Requirements: Federal regulations mandate effective internal controls to ensure accurate and complete reporting for federal awards, which were not followed in this case.
  • Recommended Follow-Up: The Department should create and document policies for independent review and approval of all federal program reports before submission to ensure accuracy and compliance.

Finding Text

Assistance Listings number and name: 21.032 COVID-19 - Local and Tribal Consistency Fund Award number and year: 1505-0276, October 20, 2022 through March 31, 2023 Federal agency: U.S. Department of the Treasury Assistance Listings number and name: 97.141 Shelter and Services Program Award number and year: 24*039, March 1, 2023 through September 30, 2025 Federal agency: U.S. Department of Homeland Security Compliance requirement: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulation, the County’s Grants Management and Innovation Department (Department) did not develop, document, or implement internal control procedures to monitor compliance with the programs’ reporting requirements. Specifically, for 5 of 7 federal program reports we tested, the Department did not perform an independent review and approval of reports prior to submitting them to the federal grantor to ensure the reported expenditures were accurate, agreed to the County’s records, and contained only allowable expenses, as follows: • 1 annual obligation and expenditure report for the Local and Tribal Consistency Fund (LTCF) totaling $7,924,031. • 3 quarterly financial reports and 3 quarterly performance reports for the Shelter and Services Program (SSP) totaling $3,092,423. Despite lacking internal control procedures, we did not identify inaccurate program information reported to the federal agency. Effect—Without effective internal control procedures in place, there is an increased risk that the Department may not prevent or detect and correct errors on reports it submits to federal agencies, which rely on them to effectively monitor the program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ success. Further, the Department is at risk that this finding applies to other federal programs it administers. For instance, in finding 2024-104, we found errors in its reports for the Emergency Rental Assistance Program and Coronavirus State and Local Fiscal Recovery Funds federal programs the Department also administers. Cause—The Department’s management reported that it had performed independent reviews and approvals of all reports but did not maintain documentation of these independent reviews because the Department did not have a formal policy requiring a documented review and approval of its reports. Criteria—Federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). This would include developing, documenting, and implementing internal control procedures to monitor compliance with federal agency guidelines requiring the Department to report accurate and complete information for the LTCF annual obligation and expenditure report and SSP quarterly financial and performance reports.1,2 Recommendations to the Department—The Department should develop, document, and implement policies and procedures, and train responsible employees, to monitor compliance with the programs’ reporting requirements, including processes to perform and document an independent review and approval of all federal program reports before submitting them to the federal agency to ensure reports are accurate, agree to County records, and contain only allowable expenditures. The County's corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 U.S. Department of the Treasury. [2022, September]. Reporting Guidance for the Local Assistance and Tribal Consistency Fund. Retrieved 4/7/2025 from https://home.treasury.gov/system/files/136/LATCF-Reporting-Guidance.pdf. 2 U.S. Department of Homeland Security. [2023, June]. The Department of Homeland Security (DHS) Notice of Funding Opportunity (NOFO) Fiscal Year 2023 Shelter and Services Program.

Categories

Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 560023 2024-102
    Material Weakness
  • 560024 2024-102
    Material Weakness
  • 560025 2024-102
    Material Weakness
  • 560026 2024-104
    Material Weakness
  • 560027 2024-102
    Material Weakness
  • 560028 2024-102
    Material Weakness
  • 560029 2024-102
    Material Weakness
  • 560030 2024-102
    Material Weakness
  • 560031 2024-102
    Material Weakness
  • 560032 2024-104
    Material Weakness
  • 560033 2024-104
    Material Weakness
  • 560034 2024-104
    Material Weakness
  • 560035 2024-104
    Material Weakness
  • 560036 2024-104
    Material Weakness
  • 560037 2024-103
    Significant Deficiency
  • 560038 2024-102
    Material Weakness
  • 560039 2024-102
    Material Weakness
  • 560040 2024-102
    Material Weakness
  • 560041 2024-103
    Significant Deficiency
  • 1136465 2024-102
    Material Weakness
  • 1136466 2024-102
    Material Weakness
  • 1136467 2024-102
    Material Weakness
  • 1136468 2024-104
    Material Weakness
  • 1136469 2024-102
    Material Weakness
  • 1136470 2024-102
    Material Weakness
  • 1136471 2024-102
    Material Weakness
  • 1136472 2024-102
    Material Weakness
  • 1136473 2024-102
    Material Weakness
  • 1136474 2024-104
    Material Weakness
  • 1136475 2024-104
    Material Weakness
  • 1136476 2024-104
    Material Weakness
  • 1136477 2024-104
    Material Weakness
  • 1136478 2024-104
    Material Weakness
  • 1136480 2024-102
    Material Weakness
  • 1136481 2024-102
    Material Weakness
  • 1136482 2024-102
    Material Weakness
  • 1136483 2024-103
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $56.16M
97.024 Emergency Food and Shelter National Board Program $22.61M
21.023 Emergency Rental Assistance Program $9.26M
97.141 Shelter and Services Program $8.17M
21.032 Local Assistance and Tribal Consistency Fund $7.92M
17.258 Wioa Adult Program $4.75M
17.278 Wioa Dislocated Worker Formula Grants $4.11M
17.259 Wioa Youth Activities $3.39M
14.218 Community Development Block Grants/entitlement Grants $3.26M
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $2.58M
16.710 Public Safety Partnership and Community Policing Grants $2.27M
93.658 Foster Care Title IV-E $2.13M
14.267 Continuum of Care Program $1.62M
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $1.56M
93.967 Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health $1.34M
93.137 Community Programs to Improve Minority Health Grant Program $1.30M
93.069 Public Health Emergency Preparedness $1.24M
93.569 Community Services Block Grant $1.11M
17.268 H-1b Job Training Grants $1.06M
20.205 Highway Planning and Construction $970,137
14.241 Housing Opportunities for Persons with Aids $894,305
93.217 Family Planning Services $832,165
95.001 High Intensity Drug Trafficking Areas Program $829,238
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $714,682
16.812 Second Chance Act Reentry Initiative $670,853
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $645,208
93.738 Pphf: Racial and Ethnic Approaches to Community Health Program Financed Solely by Public Prevention and Health Funds $545,301
97.042 Emergency Management Performance Grants $491,735
17.277 Wioa National Dislocated Worker Grants / Wia National Emergency Grants $483,545
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $474,042
93.994 Maternal and Child Health Services Block Grant to the States $462,871
66.001 Air Pollution Control Program Support $414,622
93.940 Hiv Prevention Activities Health Department Based $406,542
93.977 Sexually Transmitted Diseases (std) Prevention and Control Grants $351,215
16.606 State Criminal Alien Assistance Program $313,031
10.904 Watershed Protection and Flood Prevention $298,039
93.788 Opioid Str $265,834
66.034 Surveys, Studies, Research, Investigations, Demonstrations, and Special Purpose Activities Relating to the Clean Air Act $254,899
66.046 Climate Pollution Reduction Grants $234,024
14.239 Home Investment Partnerships Program $225,098
16.585 Treatment Court Discretionary Grant Program $218,123
93.917 Hiv Care Formula Grants $211,617
16.575 Crime Victim Assistance $193,832
14.231 Emergency Solutions Grant Program $192,886
97.039 Hazard Mitigation Grant $192,169
15.615 Cooperative Endangered Species Conservation Fund $182,617
93.268 Immunization Cooperative Agreements $166,672
93.103 Food and Drug Administration Research $145,864
93.870 Maternal, Infant and Early Childhood Homevisiting Grant Program $135,752
84.010 Title I Grants to Local Educational Agencies $134,590
97.045 Cooperating Technical Partners $133,717
16.836 Indigent Defense $131,602
90.401 Help America Vote Act Requirements Payments $131,261
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $126,888
10.555 National School Lunch Program $110,955
10.697 State & Private Forestry Hazardous Fuel Reduction Program $106,538
93.136 Injury Prevention and Control Research and State and Community Based Programs $102,561
20.616 National Priority Safety Programs $95,228
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation�s Health $90,245
16.738 Edward Byrne Memorial Justice Assistance Grant Program $86,315
93.991 Preventive Health and Health Services Block Grant $84,718
93.568 Low-Income Home Energy Assistance $82,264
66.202 Congressionally Mandated Projects $81,162
97.067 Homeland Security Grant Program $75,000
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $67,729
20.600 State and Community Highway Safety $65,800
16.588 Violence Against Women Formula Grants $64,061
15.904 Historic Preservation Fund Grants-in-Aid $59,874
93.304 Racial and Ethnic Approaches to Community Health $58,238
16.540 Juvenile Justice and Delinquency Prevention $55,797
11.033 Middle Mile (broadband) Grant Program $53,425
81.042 Weatherization Assistance for Low-Income Persons $44,768
10.704 Law Enforcement Agreements $41,080
84.425 Education Stabilization Fund $37,382
16.U00 Justice Department $31,181
93.667 Social Services Block Grant $30,038
94.006 Americorps State and National 94.006 $28,423
84.027 Special Education Grants to States $26,506
93.597 Grants to States for Access and Visitation Programs $25,446
10.553 School Breakfast Program $22,271
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $16,840
93.959 Block Grants for Prevention and Treatment of Substance Abuse $12,281
45.310 Grants to States $11,058
84.424 Student Support and Academic Enrichment Program $10,015
93.558 Temporary Assistance for Needy Families $9,993
16.582 Crime Victim Assistance/discretionary Grants $4,973