Finding Text
Condition: The Bureau did not provide evidence of having prepared or submitted the required quarterly Federal Financial Reports (SF-425) or equivalent COR3 financial status reports for FEMA Public Assistance Program ALN 97.036; despite repeated audit requests, no SF-425s or alternative reports demonstrating cumulative expenditures, federal share, or matching funds were made available, and therefore compliance with federal and pass-through reporting requirements could not be verified. Criteria: Under 2 CFR 200.328(a) and 200.302(b)(5), recipients and subrecipients must submit accurate, complete, and timely financial reports as prescribed by the awarding agency, including quarterly SF-425 (or COR3) reports; reporting deadlines for SF-425s are generally January 30, April 30, July 30, and October 30. Context: During the audit, the Bureau did not provide SF-425 reports for FEMA grants, preventing the auditors from verifying whether reports were prepared, submitted timely, or reconciled to PRIFAS accounting records; similar deficiencies were identified in prior audits (Findings 2016-03, 2019-06, and 2020-05), indicating the condition remains uncorrected and systemic. Cause: The Bureau lacks effective internal controls assigning responsibility for preparing, reviewing, and submitting SF-425 or COR3 financial reports, and there is no monitoring mechanism to ensure reports are completed and submitted by required due dates. Effect: Failure to prepare and submit required financial reports constitutes noncompliance with Uniform Guidance and FEMA/COR3 grant conditions, impedes grantor oversight of project progress and expenditure status, increases the risk of questioned costs or delayed reimbursements, and may result in sanctions such as suspension of funding or withholding of future obligations until reports are submitted and accepted. Recommendation: The Bureau should establish and enforce written procedures to ensure SF-425 or COR3 financial reports are prepared, reviewed, and submitted within prescribed deadlines, assign reporting responsibilities to specific personnel, implement a monitoring calendar to track compliance, and ensure reports are supported by reconciled accounting data from PRIFAS and other reporting systems. Questioned Costs: None. Management Response: See corrective action plan.