Finding Text
2024-044 - Untimely Submission of Required Performance Reports Federal Programs 23.002 - Appalachian Area Development (ARC) Award Numbers ARC MS-20698 ARC MS~20699 Federal Agency Appalachian Regional Commission (ARC) Compliance Requirement Reporting - 2 CFR §200.328 and §200.303 Type of Finding Internal Control over Compliance - Significant Deficiency Compliance - Noncompliance Questioned Costs None. The reporting noncompliance did not affect the allowability of costs charged to the grant. Criteria 2 CFR §200.328(b)(1) requires recipients to submit performance reports at intervals required by the federal awarding agency or pass-through entity. These reports must contain a comparison of actual accomplishments to the objectives of the award and be submitted in accordance with the terms and conditions of the grant. 2 CFR §200.303 requires recipients to establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations, and the terms and conditions of the award. This includes controls over timely and accurate reporting. Under the ARC grant agreements, semi-annual performance reports are required to be submitted within 15 days following the end of each six-month reporting period. Condition The City did not submit required semi-annual performance reports for ARC grants MS-20698 and MS-20699 within the timeframes established by the grant agreements. Reports were submitted significantly past the 15-day deadline following the end of each six-month reporting period. In some cases, multiple reports were submitted on the same day, and one report due during the audit period had not been filed as of fieldwork completion. Additionally, the reports lacked clear identification of the reporting period covered. Cause The City did not have adequate procedures in place to ensure timely tracking and submission of required performance reports. Internal controls over reporting deadlines were not operating effectively. Effect Failure to submit timely and complete performance reports limits the pass-through entity's and federal awarding agency's ability to monitor project progress and ensure compliance with grant terms. This represents noncompliance with federal reporting requirements and a deficiency in internal control over federal programs. Recommendation We recommend the City implement procedures to ensure timely submission of required performance reports, including: Maintaining a reporting calendar with automated reminders Assigning responsibility for monitoring deadlines Retaining documentation that clearly identifies the reporting period covered Views of Responsible Officials Management concurs with the finding. The City acknowledges that performance reports were submitted late and that documentation lacked clarity regarding the reporting periods. To address this, the City will implement a reporting calendar with automated reminders and assign staff responsibility for monitoring deadlines. A standardized reporting template will be adopted to ensure each submission clearly identifies the reporting period covered. These measures will strengthen internal controls and improve compliance with ARC reporting requirements.