Finding Text
Federal Program Information:
Federal Assistance Listing Number: 21.027
Federal Program Name: Coronavirus State and Local Fiscal
Recovery Funds (CSLFRF)
Federal Agency: U.S. Department of Treasury
Federal Award Number: None
Federal Award Year: March 3, 2021 to December 31, 2024
Criteria:
The American Rescue Plan Act (ARPA) specifies that eligible expenditures must align with the
period of performance requirements established by the U.S. Department of the Treasury
(Treasury). According to Treasury guidelines, the period of performance for CLSFRF begins on
March 3, 2021, meaning recipients may only use funds to cover costs incurred during the period
beginning on March 3, 2021, pursuant to the Final Rule at 31 CFR section 35.5(a).
Condition:
During the audit of CSLFRF expenditures, we identified $13,834 in costs that were incurred
before March 3, 2021, which is outside the allowable period of performance established under
the Treasury guidelines.
Cause and Effect:
The CSLFRF program, introduced under ARPA in 2021, presented new grant management
and reporting challenges for the City, which had no prior experience navigating these
requirements. As a result, $13,834 in expenditures incurred before March 3, 2021, were
misclassified, falling outside the allowable performance period defined by Treasury guidelines.
However, the City has since identified and allocated other eligible expenditures to
appropriately replace the $13,834. The City attempted to update the expenditures report filed
with the Treasury Department but was unsuccessful.
Questioned Cost:
None.
Recommendation:
To ensure compliance with Treasury guidelines, the City should strengthen its grant
management procedures by verifying that expenditures align with the approved period of
performance before reporting. Staff training on CSLFRF requirements will help improve
accuracy, while enhanced internal controls, including independent expenditure reviews, will
reduce the risk of misclassification. Lastly, establishing a process for consulting federal grant
administrators when needed will ensure clarity and compliance in expenditure reporting.
Views of Responsible Officials and Planned Corrective Action:
Consistent with Management’s Response to Audit Finding SA 2023-002, the City’s grant
processes have been updated to ensure that grants administration and reporting are compliant
with individual grant requirements and that there is interdepartmental coordination to ensure
appropriate monitoring, reviews, and reporting. Training will also be provided to all departmental
managers and Finance staff involved in grants administration, accounting, and reporting.
Responsible Personnel Name and Position: Jill Taura, Interim Finance Director
Expected Implementation Date of Corrective Action Plan: Fiscal year 2026