SCHEDULE OF FEDERAL AWARD FINDINGS AND QUESTIONED COSTS City of Cheney January 1, 2024 through December 31, 2024 2024-001 The City did not have adequate internal controls for ensuring compliance with federal allowable costs, matching and reporting requirements, and it did not comply with federal allowable costs and matching requirements. Assistance Listing Number and Title: 15.504, Water Recycling and Desalination Construction Programs Federal Grantor Name: Department of the Interior, Bureau of Reclamation Federal Award/Contract Number: R24AP00088-00 Pass-through Entity Name: N/A Pass-through Award/Contract Number: N/A Known Questioned Cost Amount: $2,591,967 Prior Year Audit Finding: N/A Description of Condition During fiscal year 2024, the City spent $3,763,605 in federal funding from the Water Recycling and Desalination Construction Program. The program provided funding through a cost-sharing agreement for infrastructure improvements and upgrades to the City’s wastewater treatment and reclamation plant. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of program controls. Allowable Costs and Matching Federal regulations require recipients to ensure costs charged to federal programs have not been included as a cost or used to meet cost sharing requirements of any other federally financed programs in the current or prior periods. Additionally, the federal grantor allows the City to submit reimbursement for allowable pre-award costs incurred on or after February 1, 2022, and requires the City to provide nonfederal matching funds for at least 75% of allowable project costs. Our audit found the City’s internal controls were inadequate for ensuring it charged only allowable costs to the program and for ensuring it provided matching funds from nonfederal sources. Specifically, the City charged construction costs to the program that it had already charged to another federal program, and it used costs reimbursed under the other federal program to meet part of its matching requirement. Additionally, the City charged the program for pre-award costs incurred before the program start date of February 1, 2022, without documentation of prior written approval. We consider these deficiencies in internal controls to be material weaknesses that led to material noncompliance. Reporting Federal regulations require the City to submit a Federal Financial Report (SF-425) semiannually. The City’s first SF-425 report for the program was due 30 days after the reporting period ending September 30, 2024. Our audit found the City’s internal controls were inadequate for ensuring it submitted the required SF-425 report that was due in 2024. We consider this internal control deficiency to be a significant deficiency. Cause of Condition Allowable Costs and Matching City staff responsible for managing the program tracked and reviewed project costs when preparing reimbursement requests and calculating the match but did not know the City had already reimbursed part of the costs under another federal program. Staff thought the City had been reimbursed for construction costs under a state grant and were not aware the costs were federally funded through a pass-through award. Also, City staff thought they received approval from the grantor to charge the program for pre-award costs incurred before the program start date but could not locate documentation showing approval. Reporting City staff responsible for managing the program were not aware of the requirement to prepare and submit the SF-425 report to the grantor. Effect of Condition and Questioned Costs Allowable Costs and Matching The City charged $2,591,967 of costs to the program that were unallowable because it had already charged them to another federal program. Additionally, the City charged $3,163 of costs to the program that were unallowable because it incurred the costs before the program start date. Therefore, we are questioning costs of $2,595,103. In 2024, the City matched $9,811,673 in shared costs for the program. The City matched $7,775,901 (79%) of this amount with costs reimbursed under another federal program, which is not an allowable source for the match. The City cannot assure federal grantors that it complied with matching requirements and that matching contributions are from an allowable nonfederal source. Any unsupported match contributions could result in reduced future federal awards. Reporting The City did not prepare and submit the one required SF-425 report due in 2024 to its grantor. Failing to submit the required reports diminishes the federal government’s ability to ensure accountability and transparency of federal spending. During the audit, the City subsequently submitted the report to the grantor in June 2025. Recommendation We recommend the City establish and follow internal controls to: • Ensure it charges only allowable costs to federal programs • Monitor costs used to meet matching requirements and ensure they are from allowable sources • Identify and submit all required reports for its federal programs City’s Response The City of Cheney recognizes the error in classifying a grant received from the Washington State Department of Commerce as a state grant rather than a federal pass through grant, which makes this funding source ineligible as matching funds in the funding awarded from the Department of Reclamation. The City has contacted the Department of Reclamation federal program to disclose the error and determine the required corrective action. The City of Cheney has proposed replacing the submitted reimbursement requests with City expenses as allowable matching expenses. The City is currently waiting on the Department of Reclamation for direction. The 2024 reporting error was corrected in 2025. Future projects with multiple funding sources will continue to be managed by the individual departments. The additional internal control will require the departments to meet quarterly with Finance to conduct internal audits of the reimbursement requests and completed reporting. Auditor’s Remarks We appreciate the City’s commitment to resolve this finding and thank the City for its cooperation and assistance during the audit. We will review the status of the City’s corrective action during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, section 403, Factors affecting allowability of costs, describes the cost principles for how direct costs should be charged to federal programs. Title 2 CFR Part 200, Uniform Guidance, section 306, Cost sharing or matching, describes the requirements for match contributions to be allowable under federal cost principles. Title 2 CFR Part 200, Uniform Guidance, section 328, Financial reporting, describes requirements for recipients to submit financial reports to awarding agencies.