Finding 1169719 (2024-003)

2 CFR 1000.10 gives regulatory effect to Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards set forth at 2 CFR Part 200 for the Department of Treasury. 2 CFR 200.329(c)(1) states, that non-Federal entities must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Reports submitted quarterly must be due no later than 30 calendar days after the reporting period. 31 CFR § 35.4(c) requires, in part, recipients, during the period of performance, to provide the Secretary of the U.S. Department of Treasury (the Treasury) periodic reports providing detailed accounting of the uses of funds, modifications to a State or Territory's tax revenue sources, and such other information as the Secretary may require for the administration of this section. For the Coronavirus State and Local Fiscal Recovery Funds, the Treasury issued the Final Rule, which clarified deadlines relating to Compliance and Reporting. The Treasury’s Compliance and Reporting guidance states that metropolitan cities and counties with a population below 250,000 residents that are allocated less than $10 million in State and Local Fiscal Recovery funding and non-entitlement units that are allocated less than $10 million in State and Local Fiscal Recovery funding are required to submit annual Project and Expenditure Reports. It further states annual reports will cover one calendar year and must be submitted to the Treasury by April 30th. The City’s annual Project and Expenditure Report was required to be submitted to the Treasury by April 30, 2024, however, was not submitted until June 20, 2024. The City’s failure to submit the required Project and Expenditure Report by the required date was due to lack of internal control over reporting for the program. Failure to have proper controls in place to ensure timely and accurate submission of Project and Expenditure Reports could result in the Treasury taking action against the City for failure to comply with programmatic requirements. The City should implement policies and procedures and have controls in place to ensure the Project and Expenditure Report is accurate and filed by the required due date to ensure compliance with their grantor's requirements.