Finding 1151690 (2024-002)

-
Requirement
AB
Questioned Costs
$1
Year
2024
Accepted
2025-08-29

AI Summary

  • Core Issue: The City submitted $54,366 in costs to FEMA that were found to be unallowable or unsupported.
  • Impacted Requirements: Compliance with 2 CFR §200.403, which mandates that costs must be necessary, reasonable, and well-documented.
  • Recommended Follow-Up: Review the questioned transactions, consult with FEMA for resolution, and enhance documentation processes for future reimbursements.

Finding Text

2025-002 – Questioned or Unsupported Costs Information on Federal Program United States Department of Homeland Security - Federal Emergency Management Agency (FEMA). Federal Assistance Listing Number 97.036 – Disaster Grants – Public Assistance. Compliance Requirements Activities Allowed or Unallowed / Allowable Costs and Cost Principles Criteria In accordance with 2 CFR §200.403, costs charged to a federal award must be necessary, reasonable, and allocable to the award. Additionally, costs must be adequately documented to be allowable under federal awards. Condition During our testing of activities and allowable costs for the year ended December 31, 2024, we identified seven (7) instances where the amounts requested for reimbursement were not allowed. Cause No cause could be determined. Effect The City received FEMA grant reimbursements for unallowable or unsupported costs, potentially reducing available federal funds for future emergencies. The City may also be at risk of noncompliance with FEMA cost-sharing (matching) requirements. Questioned Costs $54,366 (Federal share $40,775). Context Forty-two (42) disbursements totaling $410,854 were randomly selected for testing. We identified seven (7) exceptions. These exceptions included unsupported equipment and labor charges, duplicate payroll, duplicate material costs, and unsupported payroll. Recommendation We recommend the City review the identified transactions and consult with FEMA regarding resolution of the questioned costs. The City should also take steps to ensure that only allowable, adequately documented costs are submitted for reimbursement in the future. Management’s Response Responsible Official’s Response and Corrective Action Planned: We have reached out to FEMA and was provided this summarized response: “The project was obligated as a small project. FEMA does not adjust the funding amount unless specific conditions are met. If the applicant was stating that the actual cost for the small project was more than FEMA obligated, we would have to request what is called a New Small Project Overrun Appeal Request. But in this case, the actual cost resulted in an underrun based on the small project obligated amount. FEMA only asks for the applicants to apply the underrun amount back into the community." Management has also implemented a process to include financial oversight and review of all documents prior to submission to FEMA for reimbursement going forward. We will meet with all leadership staff to discuss documentation requirements necessary for FEMA reimbursements. Lastly, Management will only sign off on reimbursed costs after all changes to FEMA requests have been adequately documented. Implementation Date: Immediate Person Responsible for Corrective Action Plan: Chief Financial Officer, Ashley Cason

Categories

Questioned Costs Allowable Costs / Cost Principles

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
20.106 Airport Improvement Program $2.05M
11.300 Investments for Public Works and Economic Development Facilities $1.34M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $572,181
93.575 Child Care and Development Block Grant $448,632
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $125,843
14.239 Home Investment Partnerships Program $90,723
20.205 Highway Planning and Construction $60,884
21.027 Coronavirus State and Local Fiscal Recovery Funds $17,747
00.000 Usss Task Force $6,000
16.838 Comprehensive Opioid Abuse Site-Based Program $1,810
20.600 State and Community Highway Safety $1,676