Finding 1201235 (2025-008)

Prior Year Finding: No Federal Agency: Department of Homeland Security Federal Program: Homeland Security Grant Program (HSGP) City Department: Mayor’s Office of Emergency Management (OEM) Assistance Listing Number: 97.067 Federal Award Number and Year: UASIFFY21 (2/8/2024-6/30/2025) UASIFFY22 (10/26/2022-6/30/2025) UASIFFY23 (10/15/2023-6/30/2026) Pass-Through Agency: Massachusetts Executive Office of Public Safety and Security Pass-Through Identifying Number and Year: BOSTONFFY21UASI (2/8/2024-6/30/2025) BOSTONFFY2022UASI (10/26/2022-6/30/2025) BOSTONFFY23UASI (10/24/2023-6/30/2026) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per 2 CFR section 200.332(a) - Requirements for Pass-Through Entities states, in part, that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Control: Per 2 CFR section 200.303(a), 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. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: OEM omitted required federal award information from subawards it issued to their subrecipients. Context: For five of five subawards selected for testing, the subaward agreement did not include the federal award identification number and the federal award date for when the Federal agency awarded the funds to the prime recipient. Cause: OEM’s procedures and internal controls were not sufficient to ensure that subawards included all required information in accordance with 2 CFR 200.332. Effect: Noncompliance with subrecipient monitoring requirements occurred. Additionally, excluding required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program information and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Questioned costs: Undetermined. Recommendation: We recommend OEM review and enhance internal controls and procedures to ensure that required information is included in its subawards. Views of responsible officials: Management agrees with the finding.