Finding 1200787 (2025-003)

Federal Agency Name: U.S. Department of Treasury Assistance Listing Number: 21.027 Program Name: Coronavirus State and Local Fiscal Recovery Funds Finding Summary: Inaccurate reporting procedures were noted in 2 quarter’s performance reports. Corrective Action Plan: Each quarter, County grant staff report ARPA project expenditures that incurred during the reporting period in the online U.S. Department of Treasury’s COVID-19 Relief Hub (the Treasury portal). For all open projects, staff must manually enter total cumulative expenditures, current period obligations, and current period expenditures. In some cases, expenditures cannot be entered within the “Project Overview” section and must be entered separately in the “Expenditure” section of the Treasury portal, creating an additional step of manual data entry to record quarterly expenditures. The County has identified several system limitations within the Treasury portal that increase the risk of reporting errors. The Treasury portal does not calculate cumulative expenditures automatically; cumulative expenditure totals must be manually re-entered for each reporting period. Current period expenditures do not automatically roll into cumulative totals. The Treasury portal also lacks automated reconciliation or validation checks, meaning that errors in current period expenditure entries are not flagged and will not be reflected in cumulative expenditure totals. Additionally, the Treasury portal does not allow copying and pasting of data, requiring all amounts to be entered manually, which further increases the risk of data entry errors. To address these limitations and strengthen controls, County staff have implemented the following corrective actions: 1. Quarterly Project-Level Reconciliation Control A formal quarterly reconciliation process has been implemented at the individual project level. For each reporting period: • Each project expenditure that is recorded for the reporting period is reconciled to the internal project tracking spreadsheet, rather than only reconciling the total cumulative expenditures that appear on the front Project Overview page of the COVID-19 Relief Hub. o The internal tracking spreadsheet is updated quarterly using data from the General Ledger and individual ARPA project financial reports. • After entering expenditures into the Treasury portal is completed, staff re-open each project entry to verify accuracy and confirm that expenditures were entered correctly and no errors occurred. • Staff check for expenditure accuracy in both the “Project Status” and “Expenditure Status” tab in the Treasury portal, to ensure expenditures match and were recorded correctly. 2. Secondary Review Control All Treasury reports have a secondary review prior to submission. • The Grants Specialist prepares and enters the report. • The Grants and Procurement Director independently reviews reported amounts against the internal tracking spreadsheet. • Any discrepancies are resolved prior to report submission. This dual-review process provides segregation of duties and reduces the risk of undetected reporting errors. These procedures have been implemented and will be consistently applied for all future reporting periods to ensure accurate, complete, and reliable reporting. Responsible Individual(s): Ann McCauley, Grants and Procurement Director Elisa Fiaschetti, ARPA Program and Grants Specialist Anticipated Completion Date: January 2026