Finding 1171305 (2025-002)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2025
Accepted
2026-01-30
Audit: 384579
Organization: City of Asheville (NC)

AI Summary

  • Core Issue: The City failed to monitor subrecipient eligibility and did not verify required audits, risking reimbursement for unallowable costs.
  • Impacted Requirements: Non-compliance with sections 200.303 and 200.332 of the Uniform Grant Guidance regarding internal controls and subrecipient monitoring.
  • Recommended Follow-up: Implement and adhere to subrecipient monitoring policies, including reviewing audit reports and eligibility determinations.

Finding Text

U.S. Department of Housing and Urban Development Federal Program Name: Home Investment Partnership Program Assistance Listing Number 14.239 Subrecipient Monitoring Material Weakness and Material Noncompliance Finding 2025-002 Criteria: Section 200.303 of the Uniform Grant Guidance states that a non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Additionally, according to section 200.332 of the Uniform Grant Guidance, a non-federal entity must monitor the activities of the subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. Non-federal entities must also verify that a subrecipient is audited as required by the Uniform Grant Guidance. Condition: The City did not perform monitoring for subrecipient eligibility determinations and did not verify subrecipients were audited as required by the Uniform Grant Guidance. Effect: The City could be reimbursing subrecipients for unallowable costs. Cause: The City did not have an adequate process in place to ensure reviews of subrecipient activities were being completed and required audits were being completed. Questioned Costs: $262,000 Recommendation: We recommend the City ensure its subrecipient monitoring policies are followed and include procedures to review audit reports of subrecipients and review of subrecipient monitoring eligibility determinations. Views of responsible officials: Management agrees with the finding and is implementing procedures to correct this, which is further discussed in the corrective action plan.

Corrective Action Plan

2026 HOME AUDIT 1. Establish Annual Monitoring Plan ● Action: Create a formalized Annual Monitoring Plan based on subrecipient risk assessments and total annual federal funding. ○ Tiered Oversight: ■ High Risk: Required on-site visits (or deep-dive virtual audits) ■ Medium/Low Risk: Desk reviews and annual check-ins, sampling beneficiaries for eligibility. ■ Funding amount: Activities with $750,000 or more in federal funding (inclusive of all federal assistance) must undertake a single audit in addition to monitoring ● Completion Date: 2/27/2026 ● Responsible: Community Development Division Manager, Community Development Analysts ● Content: The plan will explicitly list which subrecipients are slated for which type of review each year. ● Documentation: Approved Annual Monitoring plan 2. Training and Capacity Building ● Action: All Community Development staff will undergo monitoring training ● Completion Date: 2/27/2026 ● Responsible: Community Development Manager, Community Development Analysts, Community Development Coordinator ● Content: Training will cover compliance requirements, identifying "red flags", confirming beneficiary eligibility, and internal monitoring Standard Operating Procedures and checklists. ● Documentation: Training logs and updated job aids. 3. Implementation & Execution ● Action: Initiate monitoring activities, prioritizing Higher Risk subrecipients identified in the initial assessment, and requesting single audits from subrecipients who received more than $750,000 in federal funding ● Completion Date: 6/30/2026 and on-going ● Responsible: Community Development Analysts, Community Development Coordinator ● Content: Analysts will produce written monitoring reports for each review following established policies and checklists for each program, which the Community Development Manager will sign off on. ● Documentation: Approved monitoring reports will be recorded and accessible for reference

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1171304 2025-002
    Material Weakness Repeat
  • 1171306 2025-003
    Material Weakness Repeat
  • 1171307 2025-003
    Material Weakness Repeat
  • 1171308 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $5.33M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $4.00M
20.513 ENHANCED MOBILITY OF SENIORS AND INDIVIDUALS WITH DISABILITIES $509,191
20.507 FEDERAL TRANSIT FORMULA GRANTS $489,680
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $372,238
20.516 JOB ACCESS AND REVERSE COMMUTE PROGRAM $159,883
95.001 HIGH INTENSITY DRUG TRAFFICKING AREAS PROGRAM $136,784
20.505 METROPOLITAN TRANSPORTATION PLANNING AND STATE AND NON-METROPOLITAN PLANNING AND RESEARCH $135,097
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $53,378
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $41,819
20.205 HIGHWAY PLANNING AND CONSTRUCTION $37,318
14.267 CONTINUUM OF CARE PROGRAM $23,904
16.607 BULLETPROOF VEST PARTNERSHIP PROGRAM $14,820
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $56