Finding 1151320 (2021-012)

Material Weakness
Requirement
L
Questioned Costs
-
Year
2021
Accepted
2025-08-28

AI Summary

  • Core Issue: The City misclassified $1,087,839 in premium pay and a $5,300,000 cash transfer, leading to discrepancies in the Schedule of Expenditures of Federal Awards (SEFA) and the general ledger.
  • Impacted Requirements: Non-compliance with the Compliance Supplement for Federal Awards and 2 CFR Part 200 Subpart F, risking eligibility for future federal funding.
  • Recommended Follow-Up: Strengthen SEFA preparation procedures, implement regular reconciliations, and provide staff training on federal fund accounting to ensure accurate reporting.

Finding Text

Criteria: The Compliance Supplement for Federal Awards and 2 CFR Part 200 Subpart F require that recipients accurately report federal expenditures in the Schedule of Expenditures of Federal Awards (SEFA). The SEFA must present federal award information in accordance with the prescribed format and include all relevant details for accurate reporting and compliance verification. Additionally, the Uniform Guidance, along with the ARPA grant award terms, requires that all federal funds and related expenditures be accurately recorded in the general ledger. Condition: The City expended $1,087,839 in premium pay to employees. However, this expenditure was not initially recorded in the ARPA designated general ledger fund; instead it was charged to other funding sources. As a result, the ARPA expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA) could not be reconciled to the City's general ledger records at the time of testing. Additionally, a $5,300,000 cash transfer between bank accounts associated with ARPA was not recorded in the City’s general ledger, further impairing the completeness and accuracy of ARPA fund activity reported in the City’s financial system. These discrepancies were subsequently identified and corrected by the City. Cause of Condition: Discrepancies in the reports and incorrect allocation of expenditures to the appropriate fund appear to result from inadequate accounting procedures or regular process to reconcile the general ledger to the SEFA. This lack of periodic reconciliation and review allowed misclassifications and omissions of ARPA transactions to go unnoticed, resulting in incomplete and inaccurate accounting records. Effect: The SEFA does not accurately reflect the federal expenditures of the City and this may lead to non-compliance with federal regulations and could impact the City’s eligibility for further federal funding. It also impairs the ability to ensure that ARPA funds are used appropriately and reported accurately. Recommendation: It is recommended that the City implement or strengthen procedures for preparing and reviewing the SEFA to ensure accuracy and completeness. Furthermore, verify that all federal expenditures are reported in the appropriate funds and implement regular reconciliations between the SEFA and general ledger to promptly identify and address discrepancies.. Additionally, training should be provided to staff on proper federal fund accounting and reporting practices. Questioned Cost: $ 0 Views of Responsible Official: The City partially disagrees with the finding. The classification approach used by the City was based on guidance provided by the U.S. Department of the Treasury under SLFRF. Specifically, the City elected to treat up to $10 million in ARPA funds as revenue replacement and allocated these across two fiscal years to track usage of restricted vs. unrestricted portions. However, we acknowledge that SEFA preparation should reflect expenditures as reported under Uniform Guidance regardless of internal fund classifications. In response, we are:  Updating our SEFA preparation procedures to ensure full alignment with 2 CFR §200 Subpart F;  Implementing a review and sign-off process by both Finance and Grants Management prior to submission;  Providing training to our accounting team on federal expenditure classification and SEFA reporting standards. We will also consult with our external auditors during the next reporting cycle to validate fund treatment and ensure that reporting is accurate and consistent with federal expectations.

Categories

Reporting

Other Findings in this Audit

  • 574876 2021-010
    Material Weakness
  • 574877 2021-011
    Material Weakness
  • 574878 2021-012
    Material Weakness
  • 1151318 2021-010
    Material Weakness
  • 1151319 2021-011
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.08M
16.922 Equitable Sharing Program $13,890