Finding Text
Reporting – Control Deficiency in Internal Controls over Compliance and Instance of Noncompliance. Federal Assistance Listing Number: 14.218. Federal Agency/Pass-through Entity - Program Name: Community Development Block Grants Cluster Entitlements/Special Purpose Grants. Award Number: N/A. Award Year: 2025. Questioned Costs: None Reported. Criteria or specific requirement: Prime grant recipients awarded a federal contract greater than or equal to $30,000 are subject to Federal Funding Accountability and Transparency Act (FFATA) subaward reporting requirements. The prime awardee is required to file a FFATA subaward report by the end of the month following the month in which the prime contractor awards any subcontract greater than or equal to $30,000. Condition: During our testing, the City did not file a FFATA report for two of its subrecipients that were granted the sub-award during the prior year with expenditures incurred in the current year. Context: Of the three subrecipients that received funding, two subrecipients did not have the FFATA report filed by the City. Effect: The FFATA report was not filed within 30 days of the sub-award. The failure to have the FFATA reports submitted could result in the submission of inaccurate or incomplete information to federal agencies, potentially leading to non-compliance with federal requirements, mismanagement of funds, and jeopardizing future funding. Cause: The City does not have an effective control in place to monitor reporting timelines and submission. Repeat finding: No. Recommendation: We recommend the City work to establish an internal tracking system to memorialize reporting deadlines and track the submission of required reports under the program. Views of responsible officials: Management agrees with the auditor recommendation. During the first and second quarters of fiscal year 2024-25, the City underwent personnel changes in the Affordable Housing Division, specifically with the key role of CDBG Program Coordinator. The transition created temporary gaps in institutional knowledge and disrupted workflow continuity. This caused the City to miss submissions of Federal Funding Accountability and Transparency Act (FFATA) reports. Upon discovery that the FFATA reports had been delayed, the new CDBG Program Coordinator entered the agreements into the federal reporting system to bring reporting up to date. Future subrecipient agreements will be reported to SAM.gov in a timely manner, and checklists have been updated to ensure this step is included as part of the awarding process.