FAC Explorer

Finding 1147906 (2024-006)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-07-16
Audit: 362374
Organization: City and County of Denver (CO)
Auditor: Clifton Larson Allen

AI Summary

  • Core Issue: The City failed to submit two FFATA reports on time, breaching federal compliance requirements.
  • Impacted Requirements: Non-compliance with 2 CFR Part 170 and 2 CFR Part 200 § 200.303 regarding timely reporting and documentation.
  • Recommended Follow-Up: Establish a formal process for documenting submission dates and retaining review records for FFATA reports.

Finding Text

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Community Development Block Grants/Entitlement Grants Assistance Listing Number: 14.218 Federal Award Identification Number and Year: B-19-MC-08-0005, 2019; B-20-MC-08-0005, 2020; B-21- MC-08-0005, 2021; B-20-MW-08-0005, 2020 Pass-Through Agency: None Pass-Through Number(s): N/A Award Period: 1/1/2019-9/1/2031 Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Under 2 CFR Part 170, recipients of federal awards are required to report subaward information to ensure transparency and accountability in the use of federal funds. This regulation, which implements the Federal Funding Accountability and Transparency Act of 2006 (as amended by the Digital Accountability and Transparency Act of 2014), mandates that recipients submit accurate data to the Federal Subaward Reporting System (FSRS) for publication on USAspending.gov. Specifically, 2 CFR Part 200, Part 3-L – Reporting specifically states: “…(b) Compare the award information accessed in step 2.a to the subaward/subcontract documents maintained by the recipient to assess if— (i) applicable subaward obligations /modifications have been reported, (ii) the key data elements (see above) were accurately reported and are supported by the source documentation, and (iii) the action was reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made.” Further, 2 CFR Part 200 § 200.303 requires non-Federal entities to: 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: We were unable to obtain evidence confirming the timely submission of two out of six reports reviewed. Additionally, the review process for these reports was not formally documented, and no records of the review were retained. Questioned costs: None. Context: During testing of FFATA report submissions for six subawards, we identified two instances where the awards were obligated in November 2023, but the corresponding FFATA reports were not submitted until January 11, 2024, and January 17, 2024, eleven and seventeen dates after the due date, respectively. While the content of the reports appeared appropriate, the submissions were not timely. Additionally, there was no concrete documentation of the review process either before or after submission. Transactions Tested Subaward not reported Timeliness of report unable to be determined Subaward amount incorrect1 Subaward missing key elements1 6 0 2 0 0 Dollar Amount of Tested Transactions Subaward not reported Timeliness of report unable to be determined Subaward amount incorrect11 Subaward missing key elements $1,436,927 $0 $911,927 $0 $0 Cause: The City experienced staff turnover within the Denver Economic Development & Opportunity department, and the individuals responsible for submitting the reports are no longer employed. Additionally, the City lacked a formal process to document submission dates and retain evidence of report review and approval. Effect: Failure to submit the subaward reports to FSRS in a timely manner places the Department out of compliance with federal reporting requirements and exposes it to potential federal sanctions. Additionally, the absence of documented review and approval processes undermines accountability and makes it difficult to verify compliance, increasing the risk of further scrutiny or penalties from oversight bodies. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the City establish and implement a formal process to consistently retain documentation of FFATA report submission dates, as well as evidence of the review and approval of each report submitted. Views of responsible officials: There is no disagreement with the audit finding.

Categories

Reporting Internal Control / Segregation of Duties Procurement, Suspension & Debarment Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 571454 2024-004
    Significant Deficiency
  • 571455 2024-004
    Significant Deficiency
  • 571456 2024-004
    Significant Deficiency
  • 571457 2024-004
    Significant Deficiency
  • 571458 2024-004
    Significant Deficiency
  • 571459 2024-004
    Significant Deficiency
  • 571460 2024-004
    Significant Deficiency
  • 571461 2024-004
    Significant Deficiency
  • 571462 2024-005
    Significant Deficiency
  • 571463 2024-005
    Significant Deficiency
  • 571464 2024-006
    Significant Deficiency
  • 571465 2024-006
    Significant Deficiency
  • 1147896 2024-004
    Significant Deficiency
  • 1147897 2024-004
    Significant Deficiency
  • 1147898 2024-004
    Significant Deficiency
  • 1147899 2024-004
    Significant Deficiency
  • 1147900 2024-004
    Significant Deficiency
  • 1147901 2024-004
    Significant Deficiency
  • 1147902 2024-004
    Significant Deficiency
  • 1147903 2024-004
    Significant Deficiency
  • 1147904 2024-005
    Significant Deficiency
  • 1147905 2024-005
    Significant Deficiency
  • 1147907 2024-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
20.106 Airport Improvement Program (aip), Infrastructure Investment and Jobs Act Programs, and Covid-19 Airports Programs $74.38M
97.036 Covid-19 - Disaster Grants - Public Assistance (presidentially Declared Disasters) $59.08M
93.558 Temporary Assistance for Needy Families (tanf) $28.82M
93.575 Child Care and Development Block Grant (ccdbg) $17.81M
20.500 Federal Transit Capital Investment Grants $17.04M
93.778 Grants to States for Medicaid $16.77M
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $15.23M
93.600 Head Start $15.19M
20.205 Highway Planning and Construction $14.81M
93.563 Child Support Services $11.07M
93.658 Foster Care Title IV-E $11.02M
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $9.41M
93.914 Hiv Emergency Relief Project Grants $7.97M
20.507 Federal Transit Formula Grants $7.64M
14.239 Home Investment Partnerships Program $4.93M
93.659 Adoption Assistance $4.54M
20.106 Covid-19 - Airport Improvement Program (aip), Infrastructure Investment and Jobs Act Programs, and Covid-19 Airports Programs $4.02M
93.667 Social Services Block Grant $3.31M
14.218 Covid-19 - Community Development Block Grants/entitlement Grants $3.29M
97.024 Emergency Food and Shelter National Board Program $2.88M
14.218 Community Development Block Grants/entitlement Grants $2.81M
97.067 Homeland Security Grant Program $2.52M
20.933 National Infrastructure Investments $2.33M
93.967 Centers for Disease Control (cdc) and Prevention Collaboration with Academia to Strengthen Public Health $2.22M
17.258 Wioa Adult Program $2.12M
17.268 H-1b Job Training Grants $2.05M
14.267 Continuum of Care (coc) Program $1.93M
14.241 Housing Opportunities for Persons with Aids $1.80M
93.471 Title IV-E Kinship Navigator Program $1.76M
97.106 Securing the Cities Program $1.65M
17.207 Employment Service/wagner-Peyser Funded Activities $1.64M
16.753 Congressionally Recommended Awards $1.63M
17.259 Wioa Youth Activities $1.60M
14.251 Economic Development Initiative, Community Project Funding, and Miscellaneous Grants $1.54M
84.425 Covid-19 - Education Stabilization Fund $1.42M
16.576 Crime Victim Compensation $1.40M
93.136 Injury Prevention and Control Research and State and Community Based Programs $1.31M
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $1.13M
20.200 Highway Research and Development Program $909,011
93.323 Covid-19 - Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $870,387
17.277 Covid-19 - Wioa National Dislocated Worker Grants / Workforce Investment Act (wia) National Emergency Grants $851,837
93.472 Title IV-E Prevention Program $843,200
95.001 High Intensity Drug Trafficking Areas (hidta) Program $821,492
93.568 Low-Income Home Energy Assistance (liheap) $752,193
21.017 Social Impact Partnerships to Pay for Results Act (sippra) $750,459
93.994 Maternal and Child Health Services Block Grant to the States $743,359
93.645 Stephanie Tubbs Jones Child Welfare Services Program $720,752
17.278 Wioa Dislocated Worker Formula Grants $690,759
14.231 Emergency Solutions Grant Program $636,686
93.069 Public Health Emergency Preparedness $597,222
11.307 Economic Adjustment Assistance $592,667
93.090 Guardianship Assistance $577,993
93.569 Community Services Block Grant (csbg) $574,465
93.268 Covid-19 - Immunization Cooperative Agreements $557,559
16.741 Dna Backlog Reduction Program $541,949
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $500,569
20.600 State and Community Highway Safety $446,919
11.024 Build to Scale $430,649
10.558 Child and Adult Care Food Program (cacfp) $395,928
97.141 Shelter and Services Program $391,802
17.225 Unemployment Insurance $370,817
93.556 Marylee Allen Promoting Safe and Stable Families Program $292,089
93.558 Covid-19 - Temporary Assistance for Needy Families (tanf) $289,850
10.551 Supplemental Nutrition Assistance Program (snap) $230,414
21.023 Covid-19 - Emergency Rental Assistance Program (erap) $211,355
20.939 Safe Streets and Roads for All $202,443
15.916 Outdoor Recreation Acquisition, Development and Planning $202,347
16.922 Equitable Sharing Program $200,398
16.036 Comprehensive Forensic Dna Analysis Grant Program $193,350
10.555 National School Lunch Program $190,668
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $190,524
93.268 Immunization Cooperative Agreements $185,107
66.818 Brownfields Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Cooperative Agreements $178,857
93.556 Marylee Allen Promoting Safe and Stable Families Program $150,665
17.285 Registered Apprenticeship $146,558
16.588 Violence Against Women Formula Grants $143,001
21.027 Covid-19 - Coronavirus State and Local Fiscal Recovery Funds $138,033
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $135,000
93.747 Covid-19 - Elder Abuse Prevention Interventions Program $133,161
93.086 Healthy Marriage Promotion and Responsible Fatherhood Grants $112,380
16.575 Crime Victim Assistance $101,329
94.006 Americorps State and National 94.006 $98,294
16.738 Edward Byrne Memorial Justice Assistance Grant Program $97,662
97.042 Emergency Management Performance Grants $91,496
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $81,601
45.024 Promotion of the Arts Grants to Organizations and Individuals $80,500
87.003 Nicholas and Zachary Burt Memorial Carbon Monoxide Poisoning Prevention Grants $74,946
16.710 Public Safety Partnership and Community Policing Grants $73,275
15.435 Gomesa $72,290
84.126 Rehabilitation Services Vocational Rehabilitation Grants to States $62,390
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $53,463
93.136 Injury Prevention and Control Research and State and Community Based Programs $51,551
45.313 Laura Bush 21st Century Librarian Program $49,412
45.149 Promotion of the Humanities Division of Preservation and Access $49,247
93.991 Preventive Health and Health Services Block Grant $45,000
90.404 Hava Election Security Grants $44,771
16.320 Services for Trafficking Victims $37,561
20.616 National Priority Safety Programs $36,448
17.270 Reentry Employment Opportunities $31,599
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $31,237
93.317 Emerging Infections Programs $28,657
17.245 Trade Adjustment Assistance $24,756
93.670 Child Abuse and Neglect Discretionary Activities $23,861
93.354 Covid-19 - Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $18,030
66.605 Performance Partnership Grants $16,649
11.020 Cluster Grants $13,348
16.609 Project Safe Neighborhoods $9,908
15.904 Historic Preservation Fund Grants-in-Aid $6,946
81.000 Department of Energy $6,350
15.658 Natural Resource Damage Assessment and Restoration $5,560
10.727 Inflation Reduction Act Urban & Community Forestry Program $4,976
10.935 Urban Agriculture and Innovative Production Grants Program (uaip) $4,772
66.312 Environmental Justice Government-to-Government (ejg2g) Program $607
14.239 Covid-19 - Home Investment Partnerships Program $24