Finding 1148203 (2024-005)

Significant Deficiency
Requirement
C
Questioned Costs
-
Year
2024
Accepted
2025-07-22
Audit: 362784
Organization: City of Commerce (CA)

AI Summary

  • Core Issue: The City has inadequate cash management procedures for federal grants, leading to inconsistent review and approval of drawdowns.
  • Impacted Requirements: Compliance with Uniform Guidance is at risk due to lack of formal policies and poor communication between departments.
  • Recommended Follow-Up: Develop formal cash management policies, establish a clear review process for drawdowns, implement a tracking system, and provide staff training on federal requirements.

Finding Text

Identification of the Federal Program: Assistance Listing Number: 20.507 Assistance Listing Title: Federal Transit Cluster Federal Agency: U.S. Department of Transportation Federal Award Identification Number: CA-2020-191; CA-2021-018; CA-2021-115; CA-2022-135; CA-2023-034 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): In accordance Uniform Guidance, recipients of federal funds must establish and maintain effective internal controls over cash management to ensure that federal funds are properly drawn down, and expenditures are accurately recorded and reported. Cash drawdowns should be supported by accurate documentation, authorized by appropriate officials, and reconciled to grant expenditures. A strong internal control environment should include formal policies and procedures for cash management, clear communication between departments involved in grant management, and a system for tracking grant expenditures and drawdowns. Condition: During the audit of cash management procedures for the Federal Transit Cluster, we noted that one out of six drawdown submitted for reimbursement was not consistently reviewed or approved by the City Manager prior to submission. Additionally, three out of six drawdowns contained corrections to the amounts being charged to the grants due to errors identified after submission. Cause: The City lacks formal policies and procedures governing the review, approval, and reconciliation of cash management for federal grants. Furthermore, there is no formal process for tracking grant expenditures and drawdowns, and insufficient communication exists between the Transit Department and the Finance Department, leading to correction in drawdown requests. Effect or Potential Effect: The absence of formal cash management procedures and ineffective communication between departments increase the risk of inaccurate drawdowns, which may result in overdrawn funds, questioned costs, or noncompliance with federal requirements. Additionally, not properly reviewing and approving all drawdowns increases the risk of errors or unauthorized drawdowns. Questioned Costs: None noted. Context: See condition above for the context of the cash management finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommend the City develop and implement formal policies and procedures for cash management of federal grants, including establishing a clear process for preparing, reviewing, and approving grant drawdowns, ensuring that all drawdowns are reviewed and authorized by a designated official, such as the City Manager, prior to submission. Further, we recommend the City implement a tracking system for grant expenditures and drawdowns to ensure accuracy and compliance with grant requirements and enhance communication between the Transportation Department and Finance Department to ensure that all grant expenditures are accurately recorded and reported. We also recommend the City provide training to staff involved in grant management to ensure a clear understanding of federal cash management requirements and internal control procedures. Views of Responsible Officials: Management concurs with the finding and agrees to implement necessary corrective procedures.

Categories

Cash Management Internal Control / Segregation of Duties

Other Findings in this Audit

  • 571761 2024-005
    Significant Deficiency
  • 571762 2024-005
    Significant Deficiency
  • 571763 2024-005
    Significant Deficiency
  • 571764 2024-005
    Significant Deficiency
  • 571765 2024-005
    Significant Deficiency
  • 571766 2024-006
    Material Weakness
  • 571767 2024-006
    Material Weakness
  • 571768 2024-006
    Material Weakness
  • 571769 2024-006
    Material Weakness
  • 571770 2024-006
    Material Weakness
  • 571771 2024-006
    Material Weakness
  • 571772 2024-007
    Material Weakness Repeat
  • 571773 2024-007
    Material Weakness Repeat
  • 571774 2024-007
    Material Weakness Repeat
  • 571775 2024-007
    Material Weakness Repeat
  • 571776 2024-007
    Material Weakness Repeat
  • 571777 2024-007
    Material Weakness Repeat
  • 1148204 2024-005
    Significant Deficiency
  • 1148205 2024-005
    Significant Deficiency
  • 1148206 2024-005
    Significant Deficiency
  • 1148207 2024-005
    Significant Deficiency
  • 1148208 2024-006
    Material Weakness
  • 1148209 2024-006
    Material Weakness
  • 1148210 2024-006
    Material Weakness
  • 1148211 2024-006
    Material Weakness
  • 1148212 2024-006
    Material Weakness
  • 1148213 2024-006
    Material Weakness
  • 1148214 2024-007
    Material Weakness Repeat
  • 1148215 2024-007
    Material Weakness Repeat
  • 1148216 2024-007
    Material Weakness Repeat
  • 1148217 2024-007
    Material Weakness Repeat
  • 1148218 2024-007
    Material Weakness Repeat
  • 1148219 2024-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
16.710 Public Safety Partnership and Community Policing Grants $185,710
14.218 Community Development Block Grants/entitlement Grants $156,930
20.507 Federal Transit Formula Grants $66,060