Finding Text
2024-032 - Delayed Final Reimbursement Due to Unresolved Agency Requests Federal Programs 23.002 - Appalachian Area Development 14.228 - Community Development Block Grants/State's Program Award Numbers ARC-20698 ARC-20699 CDBG Subgrant: 1137-21-111-PF-01 Federal Agency U.S. Department of Housing and Urban Development (HUD) Appalachian Regional Commission (ARC) Compliance Requirement Reporting and Closeout- 2 CFR §§ 200.302, 200.303, and 200.344 Type of Finding: Internal Control over Compliance - Significant Deficiency Compliance - Noncompliance Questioned Costs: None Criteria: In accordance with 2 CFR §200.302 and §200.303, non-federal entities must maintain effective internal control over federal awards and ensure timely closeout. Additionally, 2 CFR §200.344 requires that closeout be completed within one year of the end of the period of performance. Condition: Final reimbursement requests for the above federal programs were submitted over a year ago. Although the granting agencies have initiated follow-up correspondence requesting additional documentation or clarification, the final payments remain outstanding as of the audit date. No resolution has been reached, and the grants remain open. Cause: The City lacks a formalized process for tracking unresolved reimbursement requests and responding to agency inquiries in a timely and coordinated manner. This has contributed to delays in resolving outstanding issues and receiving final payments. Effect: The City has not received final reimbursement for completed federal programs, resulting in delayed revenue recognition and potential strain on local resources. The extended delay also risks noncompliance with federal closeout requirements and may affect future funding eligibility. Recommendation: Implement a grant closeout protocol that includes: A centralized tracking system for final reimbursement submissions and agency correspondence Defined timelines for follow-up and escalation Clear assignment of responsibility for resolving outstanding issues Views of Responsible Officials: Management concurs with the finding. The City acknowledges that final reimbursement requests for the referenced federal programs were submitted in a timely manner; however, final payments have not been received due to ongoing correspondence and requests for additional information from the granting agencies. While staff have responded to these inquiries, the absence of a formalized tracking and escalation process has contributed to delays in resolution.