Finding 1169641 (2025-002)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-01-20
Audit: 382641
Organization: City of Great Falls, Montana (MT)
Auditor: EIDE BAILLY

AI Summary

  • Core Issue: Inaccurate reporting in CDBG program cash reports due to insufficient internal controls.
  • Impacted Requirements: Non-compliance with Uniform Guidance, Section 200.303 on maintaining effective internal controls over Federal awards.
  • Recommended Follow-Up: Implement a documented secondary review process to ensure accuracy in all report submissions.

Finding Text

U.S. Department of Housing and Urban Development, ALN # 14.218 Community Development Block Grants/Entitlement Grants Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The Uniform Guidance, Section 200.303 Internal Controls, requires that the non-Federal entity must establish and maintain documentation of effective internal controls over Federal awards that provide reasonable assurance that awards are being managed in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. Condition: During testing of reporting compliance for the CDBG program, we reviewed three quarterly PR29 Cash on Hand reports submitted to HUD. One of the three reports contained an inaccurate amount in Line 13 – Revolving Funds Received During the Reporting Period. The incorrect figure did not reflect actual program activity for the quarter, resulting in a discrepancy between reported and actual cash activity. As such, ending Cash on Hand does not agree to underlying accounting records. Additionally, we tested the annual PR26 CDBG Financial Summary Report for Program Year 2023 which was filed during the City’s current fiscal year. The City was unable to support the accuracy of the amount reported within line 5, current program income. Cause: The City’s internal review process for CDBG reporting was insufficient to detect and correct errors prior to submission. Specifically, the lack of a documented secondary review and reconciliation of source data to the PR29 and PR26 reports contributed to the inaccurate reporting within both reports. Effect: The submission of inaccurate information to HUD could lead to misinterpretation of program cash flow and compliance status. While the error was isolated, it indicates a weakness in internal controls that could result in future reporting inaccuracies, potentially impacting Federal oversight and funding decisions. Questioned Costs: None Reported Context/Sampling: A nonstatistical sample of 4 reports out of 6 were selected for Reporting testing. Repeat Finding from Prior Year: No Recommendation: We recommend the City ensure review and approval controls are in place to ensure all required reports are accurate and submitted timely. Views of Responsible Officials: Agree

Corrective Action Plan

Federal Agency Name: U.S. Department of Housing and Urban Development Program Name: Community Development Block Grants/Entitlement Grants Assistance Listing Number: 14.218 Finding Summary: One of three quarterly PR29 Cash on Hand reports submitted to HUD contained an inaccurate figure for revolving funds received on Line 13, due to insufficient internal review and reconciliation. Additionally, the amount on Line 5 on the PR26 Financial Summary Report was unable to be supported. Corrective Action Plan: The City will strengthen internal controls over CDBG reporting by: • Implementing a documented secondary review process for all PR29 and PR26 reports. • Requiring reconciliation of source data to report figures prior to submission. Responsible Individual(s): Melissa Kinzler, Finance Director Tom Hazen, Grant Administrator Anticipated Completion Date: January 2026

Categories

Reporting Internal Control / Segregation of Duties HUD Housing Programs Material Weakness Matching / Level of Effort / Earmarking Program Income

Programs in Audit

ALN Program Name Expenditures
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $2.48M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $847,224
97.017 PRE-DISASTER MITIGATION (PDM) COMPETITIVE GRANTS $351,438
12.600 COMMUNITY INVESTMENT $242,359
20.205 HIGHWAY PLANNING AND CONSTRUCTION $161,089
95.001 HIGH INTENSITY DRUG TRAFFICKING AREAS PROGRAM $95,384
12.003 COMMUNITY ECONOMIC ADJUSTMENT ASSISTANCE FOR RESPONDING TO THREATS TO THE RESILIENCE OF A MILITARY INSTALLATION $68,460
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $64,147
97.067 HOMELAND SECURITY GRANT PROGRAM $15,864
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $10,581
16.607 BULLETPROOF VEST PARTNERSHIP PROGRAM $6,605
15.904 HISTORIC PRESERVATION FUND GRANTS-IN-AID $6,000
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $4,580