Finding 1191111 (2025-002)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2025
Accepted
2026-03-27
Audit: 395258
Organization: City of Oakland (CA)

AI Summary

  • Core Issue: Duplicate payroll costs totaling $113,551 were claimed for federal reimbursement, violating compliance requirements.
  • Impacted Requirements: Costs must be allowable, reasonable, and adequately supported as per federal guidelines (2 CFR §200.403 and §200.430).
  • Recommended Follow-Up: Strengthen internal controls, implement payroll reconciliations, and provide training on federal cost allowability to prevent future issues.

Finding Text

Finding Reference: 2025-002 Federal Agency: U.S. Department of Homeland Security Pass-Through Entity: California Governor's Office of Emergency Services Federal Program Title: Disaster Grants - Public Assistance (Presidentially Declared Disasters) Assistance Listing Number: 97.036 Federal Grant Number: FEMA 4482DR-CA-01387 FEMA 4482DR-CA-01680 FEMA 4482DR-CA-02974 FEMA 4482DR-CA-03269 FEMA-4482-DR-CA-PW-00265(2) FEMA-4482-DR-CA-PW06047(3932) FEMA DR-4683 FEMA DR-4699 Category of Finding: Activities Allowed or Unallowed Allowable Costs/Cost Principles Classification of Finding: Significant Deficiency in Internal Control over Compliance Instance of Noncompliance Criteria The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR §200.403 and §200.430, require that costs charged to federal awards be allowable, reasonable, allocable, and adequately supported. Payroll costs charged to federal programs must be based on accurate payroll records and may not be duplicated or claimed more than once for reimbursement. In addition, management is responsible for establishing and maintaining effective internal control over compliance to ensure federal awards are administered in accordance with applicable laws, regulations, and grant provisions. Condition During our audit, we selected a statistically valid sample of 40 payroll transactions and identified 5 duplicate payroll transactions that were included in amounts submitted for reimbursement under the program. Specifically, certain payroll costs were charged more than once to the federal program, resulting in unallowable costs being claimed for reimbursement. These duplicate charges were not identified or corrected by management prior to submission of reimbursement requests. The City subsequently performed a detailed review of the payroll charges included in the reimbursement submissions, identified duplicate payroll charges of $113,551, and reduced the reported expenditure in the Schedule of Expenditure of Federal Awards for the year ended June 30, 2025. Cause The condition was caused by ineffective internal controls over submission of reimbursement requests, including inadequate review procedures to ensure payroll costs were not duplicated prior to submission, lack of reconciliation between payroll records and reimbursement requests, and insufficient supervisory review over payroll charges included in the reimbursement requests. Identification of Repeat Finding This is not a repeat finding in the immediate prior audit period. Effect As a result of these control deficiencies, unallowable payroll costs were claimed for federal reimbursement. This noncompliance could result in the City being required to repay the federal awarding agency and increase the risk of additional unallowable costs being claimed in future periods if not corrected. Questioned Costs Known questioned costs totaling $113,551 were identified related to duplicate payroll charges included in the reimbursement submission for grant number FEMA-4482-DR-CA-PW06047(3932). Recommendations We recommend that the City strengthen internal controls over payroll cost allocation and reimbursement processes to ensure payroll costs are not duplicated; implement reconciliations between payroll records and reimbursement requests prior to submission; and provide additional training to personnel responsible for grant accounting on federal cost allowability requirements. View of Responsible Officials and Planned Corrective Action See separately prepared Corrective Action Plan.

Corrective Action Plan

Finding 2025-002 Assistance Listing Number 97.036 Disaster Grants - Public Assistance (Presidentially Declared Disasters) Activities Allowed or Unallowed, Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Instance of Noncompliance During the COVID-19 emergency, the City faced a high volume of FEMA Public Assistance (PA) grant submissions through CalOES and engaged an outside consultant to support cost recovery efforts. While internal controls were in place, the combination of evolving program determinations, high transaction volume, and limited staffing contributed to a breakdown in tracking payroll costs across projects. Specifically, labor costs associated with the Great Plates program were initially included in an early project submission but were subsequently challenged and removed by CalOES/FEMA. These same labor costs were later included in Category Z (Cat Z) project costs. CalOES subsequently approved the previously disallowed Great Plates labor and obligated funding without additional notification. As a result, the same payroll costs were inadvertently included in both projects, and the duplication was not identified prior to submission. Following the audit, the City conducted a detailed review of labor and fringe benefit costs across all applicable projects. Through this review, the City identified duplicate payroll charges and revised the reported expenditures to remove the duplicate charges. To prevent recurrence, the City has implemented enhanced oversight and centralized tracking controls across all grant programs, including strengthened payroll cost monitoring by funding source, cross-project reconciliations prior to submission, and supervisory review of reimbursement requests to ensure costs are not duplicated, particularly when eligibility determinations change. The City will also enhance monitoring of funding determinations and obligation updates and provide ongoing staff training on federal cost allowability and documentation requirements. These measures will be applied consistently across all grants, with additional attention during high-volume or emergency response activities. Contact person responsible for corrective action: Pooja Shrestha Anticipated completion date: Partially implemented and ongoing as of March 2026; full implementation by June 30, 2026

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1191104 2025-002
    Material Weakness Repeat
  • 1191105 2025-002
    Material Weakness Repeat
  • 1191106 2025-002
    Material Weakness Repeat
  • 1191107 2025-002
    Material Weakness Repeat
  • 1191108 2025-002
    Material Weakness Repeat
  • 1191109 2025-002
    Material Weakness Repeat
  • 1191110 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.600 HEAD START $12.39M
97.083 STAFFING FOR ADEQUATE FIRE AND EMERGENCY RESPONSE (SAFER) $7.69M
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $5.85M
14.267 CONTINUUM OF CARE PROGRAM $2.28M
93.778 MEDICAL ASSISTANCE PROGRAM $1.69M
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $1.15M
17.259 WIOA YOUTH ACTIVITIES $984,228
97.025 NATIONAL URBAN SEARCH AND RESCUE (US&R) RESPONSE SYSTEM $845,235
20.205 HIGHWAY PLANNING AND CONSTRUCTION $837,697
97.056 PORT SECURITY GRANT PROGRAM $468,314
93.493 CONGRESSIONAL DIRECTIVES $371,871
16.839 STOP SCHOOL VIOLENCE $364,833
17.258 WIOA ADULT PROGRAM $362,745
66.126 GEOGRAPHIC PROGRAMS - SAN FRANCISCO BAY WATER QUALITY IMPROVEMENT FUND $311,003
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $298,668
94.016 AMERICORPS SENIORS SENIOR COMPANION PROGRAM (SCP) 94.016 $279,779
17.278 WIOA DISLOCATED WORKER FORMULA GRANTS $277,092
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $268,258
93.569 COMMUNITY SERVICES BLOCK GRANT $240,156
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $203,873
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $200,000
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $165,000
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $160,081
16.045 COMMUNITY-BASED VIOLENCE INTERVENTION AND PREVENTION INITIATIVE $145,833
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $142,361
10.558 CHILD AND ADULT CARE FOOD PROGRAM $127,993
14.241 HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS $120,941
10.727 INFLATION REDUCTION ACT URBAN & COMMUNITY FORESTRY PROGRAM $107,238
16.742 PAUL COVERDELL FORENSIC SCIENCES IMPROVEMENT GRANT PROGRAM $62,611
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $59,512
16.817 BYRNE CRIMINAL JUSTICE INNOVATION PROGRAM $55,685
16.753 CONGRESSIONALLY RECOMMENDED AWARDS $46,071
97.067 HOMELAND SECURITY GRANT PROGRAM $34,759
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $23,166
94.011 AMERICORPS SENIORS FOSTER GRANDPARENT PROGRAM (FGP) 94.011 $10,471
16.741 DNA BACKLOG REDUCTION PROGRAM $8,126
16.034 CORONAVIRUS EMERGENCY SUPPLEMENTAL FUNDING PROGRAM $4,000